U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2008-026 

Programmatic Environmental 

Assessment for Grid 9 

Site-Specific Evaluation of Energy Resource 

Technology, Inc.’s Supplemental Development 

Operations Coordination Document, S-7156 

Phoenix Project 

Green Canyon Blocks 236 and 237 
U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2008-026 

Programmatic Environmental 

Assessment for Grid 9 

Site-Specific Evaluation of Energy Resource 

Technology, Inc.’s Supplemental Development 

Operations Coordination Document, S-7156 

Phoenix Project 

Green Canyon Blocks 236 and 237 

Author 

Minerals Management Service 

Gulf of Mexico OCS Region 

Published by 

New Orleans

May 2008 

v 

TABLE OF CONTENTS 

Page 

FINDING OF NO SIGNIFICANT IMPACT ..............................................................................................iii

FIGURES.....................................................................................................................................................ix

TABLES ......................................................................................................................................................ix

ABBREVIATIONS AND ACRONYMS ....................................................................................................xi

INTRODUCTION ........................................................................................................................................1

1. PROPOSED ACTION ............................................................................................................................9

1.1. Purpose of the Proposed Action..................................................................................................9

1.2. Need for the Proposed Action.....................................................................................................9

1.3. Description of the Proposed Action ............................................................................................9

1.3.1. Proposed Action ...........................................................................................................9

1.3.2. Background ................................................................................................................10

1.3.3. Schedule of Activities ................................................................................................10

1.3.4. Equipment and Drilling System .................................................................................11

1.3.5. Support Facilities........................................................................................................11

1.3.6. Transportation Operations..........................................................................................12

1.3.7. New and Unusual Technology ...................................................................................12

1.3.8. Impacts from Potential Geological Hazards...............................................................12

1.4. Offshore Discharges and Waste Disposal.................................................................................12

1.5. Potential Impact-Producing Factors..........................................................................................13

1.6. Regulatory Framework .............................................................................................................15

2. ALTERNATIVES CONSIDERED ......................................................................................................15

2.1. Nonapproval of the Proposal.....................................................................................................15

2.2. Approval with Existing Mitigation ...........................................................................................15

2.3. Approval with Existing and/or Added Mitigation ....................................................................15

3. DESCRIPTIONS AND IMPACT ANALYSES OF THE AFFECTED RESOURCES.......................15

3.1. Physical Resources....................................................................................................................15

3.1.1. Water Quality .............................................................................................................16

3.1.1.1. Coastal Waters ..........................................................................................16

3.1.1.1.1. Description .............................................................................16

3.1.1.1.2. Impact Analysis......................................................................16

3.1.1.1.3. Cumulative Analysis ..............................................................17

3.1.1.2. Offshore Waters ........................................................................................18

3.1.1.2.1. Description .............................................................................18

3.1.1.2.2. Impact Analysis......................................................................20

3.1.1.2.3. Cumulative Analysis ..............................................................21
vi 

3.1.2. Air Quality..................................................................................................................21

3.1.2.1. Description................................................................................................21

3.1.2.2. Impact Analysis.........................................................................................22

3.1.2.3. Cumulative Analysis .................................................................................22

3.2 Biological Resources.................................................................................................................22

3.2.1. Sensitive Coastal Resources.......................................................................................22

3.2.1.1. Coastal Barrier Beaches and Associated Dunes........................................23

3.2.1.1.1. Description .............................................................................23

3.2.1.1.2. Impact Analysis......................................................................24

3.2.1.1.3 Cumulative Analysis ..............................................................25

3.2.1.2. Wetlands....................................................................................................26

3.2.1.2.1 Description .............................................................................26

3.2.1.2.2. Impact Analysis......................................................................27

3.2.1.2.3. Cumulative Analysis ..............................................................28

3.2.1.3. Alabama, Choctawhatchee, St. Andrew, and Perdido Key Beach Mice...29

3.2.1.3.1. Description .............................................................................29

3.2.1.3.2. Impact Analysis......................................................................30

3.2.1.3.3. Cumulative Analysis ..............................................................30

3.2.2. Sensitive Offshore Resources.....................................................................................31

3.2.2.1. Deepwater Benthic Communities .............................................................31

3.2.2.1.1. Nonchemosynthetic Communities .........................................31

3.2.2.1.1.1. Description.......................................................31

3.2.2.1.1.2. Impact Analysis ...............................................32

3.2.2.1.1.3. Cumulative Analysis........................................33

3.2.2.1.2. Chemosynthetic Communities ...............................................33

3.2.2.1.2.1. Description.......................................................33

3.2.2.1.2.2. Impact Analysis ...............................................34

3.2.2.1.2.3. Cumulative Analysis........................................34

3.2.2.2. Marine Mammals ......................................................................................35

3.2.2.2.1. Description .............................................................................35

3.2.2.2.2. Impact Analysis......................................................................35

3.2.2.2.3. Cumulative Analysis ..............................................................36

3.2.2.3. Sea Turtles.................................................................................................37

3.2.2.3.1. Description .............................................................................37

3.2.2.3.2. Impact Analysis......................................................................37

3.2.2.3.3. Cumulative Analysis ..............................................................39

3.2.2.4. Essential Fish Habitat and Fish Resources................................................39

3.2.2.4.1. Description .............................................................................39

3.2.2.4.2. Impact Analysis......................................................................40

3.2.2.4.3. Cumulative Analysis ..............................................................41

3.2.2.5. Gulf Sturgeon............................................................................................41

3.2.2.5.1. Description .............................................................................41

3.2.2.5.2. Impact Analysis......................................................................42

3.2.2.5.3. Cumulative Analysis ..............................................................43

3.2.2.6. Coastal and Marine Birds..........................................................................43

3.2.2.6.1. Description .............................................................................43

3.2.2.6.2. Impact Analysis......................................................................45

3.2.2.6.3. Cumulative Analysis ..............................................................46

3.3. Socioeconomic and Human Resources .....................................................................................47

3.3.1. Socioeconomic Resources..........................................................................................47

3.3.1.1. Socioeconomic Impact Area .....................................................................47
vii 

3.3.1.2. Commercial Fisheries................................................................................48

3.3.1.2.1. Description .............................................................................48

3.3.1.2.2. Impact Analysis......................................................................48

3.3.1.2.3. Cumulative Analysis ..............................................................49

3.3.1.3. Recreational Resources .............................................................................50

3.3.1.3.1. Description .............................................................................50

3.3.1.3.2. Impact Analysis......................................................................50

3.3.1.3.3. Cumulative Analysis ..............................................................51

3.3.1.4. Archaeological Resources.........................................................................51

3.3.1.4.1. Description .............................................................................51

3.3.1.4.2. Impact Analysis......................................................................51

3.3.1.4.3. Cumulative Analysis ..............................................................52

3.3.2. Human Resources and Land Use................................................................................52

3.3.2.1. Population .................................................................................................53

3.3.2.1.1. Description .............................................................................53

3.3.2.1.2. Impact Analysis......................................................................53

3.3.2.1.3. Cumulative Analysis ..............................................................53

3.3.2.2. Infrastructure and Land Use......................................................................54

3.3.2.2.1. Description .............................................................................54

3.3.2.2.2. Impact Analysis......................................................................54

3.3.2.2.3. Cumulative Analysis ..............................................................55

3.3.2.3. Employment ..............................................................................................55

3.3.2.3.1. Description .............................................................................55

3.3.2.3.2. Impact Analysis......................................................................57

3.3.2.3.3. Cumulative Analysis ..............................................................57

3.3.2.4. Environmental Justice ...............................................................................58

3.3.2.4.1. Description .............................................................................58

3.3.2.4.2. Impact Analysis......................................................................58

3.3.2.4.3. Cumulative Analysis ..............................................................59

4. CONSULTATION AND COORDINATION ......................................................................................59

5. REFERENCES .....................................................................................................................................59

6. PREPARERS ........................................................................................................................................68

7. APPENDICES ......................................................................................................................................69

Appendix A. Waste and Discharges Review....................................................................................A-3

Appendix B. Accidental Oil-Spill Review ....................................................................................... B-3
ix 

FIGURES 

Page 

Figure 1. Relationship of Grid 9 to the Gulf Coastline and to Other Grids Defined in MMS’s 

Comprehensive Deepwater Development Strategy. ...............................................................2

Figure 2. Areas and Blocks in Grid 9 with the Location of the Proposed Phoenix Project....................3

Figure 3. Bathymetric Map of Grid 9.....................................................................................................4

Figure 4. Military Warning Areas Proximal to Grid 9. ..........................................................................5

Figure 5. Active Lease Status and Plans Submitted in Grid 9................................................................7

Figure 6. Distances from the Phoenix Project in Green Canyon Blocks 236 and 237 to the Primary 

Shore Bases in Port Fourchon, Louisiana. ..............................................................................8

TABLES 

Page 

Table 1. Protraction Areas, Blocks, and Leases in Grid 9 ....................................................................4

Table 2. Grid 9 Military Warning Areas and Headquarters Addresses.................................................6

Table 3. Owners and/or Leasholders in Grid 9 .....................................................................................6

Table 1-1. Surface Locations of the Proposed Wells, Floating Production Unit, Disconnectable 

Transfer System, and Pipeline End Manifold .......................................................................10

Table 1-2. Schedule for Pipelaying, Drilling, Completion, and Production from Green Canyon 

Blocks 236 and 237...............................................................................................................11

Table 1-3. Support Vessel and Frequency..............................................................................................12

Table 1-4. Projected Ocean Discharges from the Phoenix Project......................................................... 13
xi 

ABBREVIATIONS AND ACRONYMS 

ac acre 

bbl barrel 

BOD biochemical oxygen demand 

BSL below sea level 

CFR Code of Federal Regulations 

CO carbon monoxide 

CPA Central Planning Area 

CZM Coastal Zone Management 

DOCD Development Operations Coordination Document 

DOI Department of the Interior 

DP dynamically positioned 

DTS disconnectable transfer system 

E&P exploration and production 

EFH essential fish habitat 

EIA economic impact area 

EIS environmental impact statement 

EPA Eastern Planning Area 

ERT Energy Resource Technology, Inc. 

ESA Endangered Species Act 

FAA Federal Aviation Administration 

FEL from the east block line 

FPU floating production unit 

FNL from the north block line 

FSL from the south block line 

ft feet 

FWL from the west block line 

gal gallon 

GC Green Canyon 

GMFMC Gulf of Mexico Fishery Management Council 

GOM Gulf of Mexico 

GS Geological Survey 

ha hectares 

H2S hydrogen sulfide 

km kilometer 

L liter 

LA Hwy 1 Louisiana Highway 1 

LMA Labor Market Area 

m meter 

MARPOL International Convention for the Prevention of Pollution from Ships 

mi mile 

MMS Minerals Management Service 

MODU mobile offshore drilling unit 

MWA Military Warning Area 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NERBC New England River Basins Commission 

NMFS National Marine Fisheries Service 

NOx nitrogen oxides 

NO2 nitrogen dioxide 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge and Elimination System 

NRC National Research Council 

NTL Notice to Lessees and Operators 
xii 

OCS Outer Continental Shelf 

OCSLA Outer Continental Shelf Lands Act 

PAH polynuclear aromatic hydrocarbon 

PCB polychlorinated biphenyl 

PEA Programmatic Environmental Assessment 

PM particulate matter 

ppt parts per thousand 

PSD Prevention of Significant Deterioration 

QCDC Quick Connect Disconnect Connector 

ROV remotely operated vehicle 

SBF synthetic-based fluid 

SOV spill occurrence variable 

SOx sulphur oxides 

SWAMP Sperm Whale Acoustic Monitoring Program 

SWSS Sperm Whale Seismic Study 

TLP tension-leg platform 

TV transport variable 

U.S. United States 

USDOC U.S. Department of Commerce 

USDOI U.S. Department of the Interior 

USDOT U.S. Department of Transportation 

USEPA U.S. Environmental Protection Agency 

USCG U.S. Coast Guard 

VOC volatile organic compounds 

WBF water-based fluid 

WPA Western Planning Area 

yr year 
1 

INTRODUCTION 

The Minerals Management Service (MMS) developed a comprehensive strategy for postlease 

National Environmental Policy Act (NEPA) compliance for development and production projects in 

deepwater areas (water depths greater than 400 meters (m) (1,312 feet (ft)) in the Central Planning Area 

(CPA) and Western Planning Area (WPA) of the Gulf of Mexico (GOM). The strategy led to the 

development of a biologically-based grid system to ensure broad and systematic analysis of the GOM’s 

deepwater region, which is explained on MMS’s website at http://www.mms.gov. This strategy divides 

the deepwater Gulf into 18 areas or “grids” of biological similarity, which generally correlate to water 

depth. 

The area for this programmatic environmental assessment (PEA) is Grid 9 in the CPA. Grid 9 is a 

portion of the Outer Continental Shelf (OCS) in water depths between 400 and 1,000 m (1,312 and 3,280 

ft). Figure 1 shows the relationship of Grid 9 to the Gulf’s coastline and the other 17 grids. This PEA 

characterizes the environment of Grid 9 and examines the potential impacts that may result from the sitespecific activities proposed by Energy Resource Technology, Inc. (ERT) in its Supplemental 

Development Operations Coordination Documents (DOCD) (Plan Number S-7156) for their proposed 

Phoenix Project. ERT proposes to use a floating production unit (FPU) to receive and export produced 

oil and gas. The MMS has determined that the Phoenix Project is a suitable project on which to base this 

PEA since it proposes to install surface facilities in waterdepths >400 m (1,312 ft) and is centrally located 

in and representative of Grid 9. 

The PEA is designed to be comprehensive in terms of (1) characterizing the physical, biological, and 

socioeconomic resources within the grid, (2) describing the impact-producing factors from this proposed 

development project, (3) describing the potential impacts from this specific proposal that are 

representative of the grid, and (4) considering the cumulative impacts from OCS development activity 

within Grid 9. Figure 2 shows the location of the proposed Phoenix Project in Green Canyon Blocks 236 

and 237 (OCS-G 15562 and 15563, respectively) in relationship to the 221 OCS blocks that comprise 

Grid 9. 

The Grid 9 PEA serves as a reference document for the tiering (40 CFR 1502.20) concept detailed in 

NEPA’s implementing regulations and allows subsequent environmental analyses for individual plans 

proposed within the grid to focus on specific issues and effects within Grid 9. This PEA tiers primarily 

from Gulf of Mexico OCS Oil and Gas Lease Sales: 2007-2012; Western Planning Area Sales 204, 207, 

210, 215, and 218; Central Planning Area Sales 205, 206, 208, 213, 216, and 222; Final Environmental 

Impact Statement; Volumes I and II (Multisale EIS) (USDOI, MMS, 2007). Relevant information from 

the Multisale EIS is hereby incorporated by reference into this PEA. 

Current Status of Grid 9 

Figure 1 shows the relationship of Grid 9 to the Gulf’s coastline and the other 17 grids that have been 

defined in MMS’s comprehensive strategy for postlease NEPA compliance in deepwater areas of the 

GOM. The nearest land to Grid 9 is in Isle Denieres in Terrebonne Parish, Louisiana, approximately 70 

miles (mi) (113 kilometers (km)) to the north (Figure 1). Figure 2 shows the OCS protraction areas and 

blocks within Grid 9 and the location of the Phoenix Project in Green Canyon Blocks 236 and 237. 
2

Figure 1. Relationship of Grid 9 to the Gulf Coastline and to Other Grids Defined in MMS’s Comprehensive Deepwater Dev
3 

Figure 2. Areas and Blocks in Grid 9 with the Location of the Proposed Phoenix Project. 

Table 1 summarizes the statistics for the OCS areas of Green Canyon, Ewing Bank, and Garden 

Banks, which constitute Grid 9. Green Canyon constitutes about 89 percent of the total number of blocks 

in Grid 9 and about 90 percent of the total number of leases. Ewing Bank constitutes 3 percent of the 

total number of blocks in Grid 9 and about 3 percent of the total leases; Garden Banks contains the 

remaining 8 percent of the total number of blocks in Grid 9 and 7 percent of the total leases. About 78 

percent of all blocks in the grid are leased. Figure 3 shows the bathymetry of Grid 9. Figure 4 shows the 

location of the Military Warning Areas (MWA’s) relative to Grid 9. About 30 percent of Grid 9 (70 

whole and partial blocks) lies within portions of three MWA’s. Approximately 1 percent (approximately 

3 whole and partial blocks) of Grid 9 lies in MWA W-147AB, approximately 6.5 percent (approximately 

15 whole and partial blocks) lies in MWA W-59A, and approximately 23 percent (approximately 51 

whole and partial blocks) lies within MWA W-92. Green Canyon Blocks 236 and 237 lie outside the 

three MWA’s. Although Green Canyon Blocks 236 and 237 lie outside the above-mentioned MWA’s, 

the lessee is required to enter into an agreement with the commander of the individual headquarters, listed 

in Table 2, upon utilizing an individual designated warning area prior to commencing an operation on its 
4 

behalf, via a boat, ship, or a aircraft traffic into one of the MWA’s. Such an agreement will provide for 

the positive control of boats, ships, and aircraft operating into the warning areas at all times. 

Table 1 

 

Protraction Areas, Blocks, and Leases in Grid 9 

Protraction Area No. of Grid Blocks No. of Grid 

Blocks Leased 

Percentage of Grid 

Blocks Leased 

Green Canyon 197 155 77 

Ewing Bank 6 5 83 

Garden Banks 18 12 67 

Grid Totals 221 172 78 

Figure 3. Bathymetric Map of Grid 9. 
5 

Figure 4. Military Warning Areas Proximal to Grid 9. 
6 

Table 2 

 

Grid 9 Military Warning Areas and Headquarters Addresses 

Military Warning Area Command Headquarters 

W-59 Naval Air Station 

JRB 159 Fighter Wing 

400 Russell Avenue, Box 27 

Building 285 

New Orleans, Louisiana 70143-0027 

Telephone: (504) 391-8696 

W-92 Naval Air Station 

Air Operations Department 

Air traffic Division/Code 52 

400 Russell Avenue, Building 1 

New Orleans, Louisiana 70143-0027 

Telephone: (504) 678-3101 

W-147 147 OG/DOV 

14657 Sneider Street 

Houston, Texas 77034-5586 

Telephone: (281) 929-2142 

Operators and/or leaseholders in Grid 9 are shown in Table 3. At present, there are 33 operators and/

or leaseholders in Grid 9. These operators include major international oil and gas operators as well as 

independent companies. This listing reflects MMS’s databases at the time this PEA was written. Interest 

by leasehold may vary over time. 

Table 3 

 

Owners and/or Leasholders in Grid 9 

Anadarko E&P Company LP LLOG Exploration Offshore, Inc. 

BHP Billiton Petroleum (GOM) Inc. Marathon Oil Company 

BP Exploration & Production Inc. Mariner Energy, Inc. 

Capco Offshore, Inc. Marubeni Oil & Gas (USA) Inc. 

Chevron U.S.A. Inc. Murphy Exploration & Production Company—USA 

Cobalt International Energy, L.P. Nexen Petroleum Offshore U.S.A. Inc. 

ConocoPhillips Company Nexen Petroleum U.S.A. Inc. 

Davis Offshore, L.P. Noble Energy, Inc. 

Deep Gulf Energy LP Plains Exploration & Production Company 

Devon Energy Production Company, L.P. Remington Oil and Gas Corporation 

Energy Resource Technology, Inc. Repsol E&P USA Inc. 

Energy XXI GOM, LLC Royal Production Company, Inc 

Eni US Operating Co. Inc. Shell Offshore Inc. 

Exxon Mobil Corporation Stone Energy Corporation 

Hess Corporation W&T Offshore, Inc. 

Hydro Gulf of Mexico, L.L.C. Walter O & G Corporation 

Kerr-McGee Oil & Gas Corporation 

The type of lease and the status of plans that have been submitted in Grid 9 are shown in Figure 5. In 

Grid 9, there were 94 exploration plans and 52 DOCD’s approved by MMS. Nineteen blocks have been 

designated by their operators as unit developments. 
7 

Figure 5. Active Lease Status and Plans Submitted in Grid 9. 

ERT has chosen Port Fourchon, Louisiana, as its onshore base to support its offshore operations for 

the Phoenix Project. This base is widely used by industry. There are numerous onshore support bases 

that are available along the Gulf Coast and that could serve as logistical infrastructure for Grid 9. 

Figure 6 shows the distances from the Phoenix Project in Green Canyon Blocks 236 and 237 to ERT’s 

chosen shore base. 
8 

Figure 6. Distances from the Phoenix Project in Green Canyon Blocks 236 and 237 to the 

Primary Shore Bases in Port Fourchon, Louisiana, and the Closest Shoreline. 
9 

1. PROPOSED ACTION 

1.1. PURPOSE OF THE PROPOSED ACTION

The purpose of the proposed action outlined by ERT in their DOCD is to drill, complete, and produce 

the hydrocarbon resources in Green Canyon Blocks 236 and 237. Exploration, discovery, and production 

of hydrocarbon resources would help satisfy the Nation’s need for energy. Under the Outer Continental 

Shelf Lands Act (OCSLA), as amended, the Department of the Interior (DOI) is required to manage the 

orderly leasing, exploration, development, and production of oil and gas resources on the Federal OCS. 

The Secretary of the Interior oversees the OCS oil and gas program and MMS is the agency charged with 

this oversight. The Secretary is required to balance orderly resource development with protection of the 

human, marine, and coastal environments while ensuring that the U.S. public receives an equitable return 

for resources discovered and produced on public lands. 

1.2. NEED FOR THE PROPOSED ACTION

As the designated operator of Green Canyon Blocks 236 and 237, ERT filed a DOCD with MMS 

consistent with its obligation to file such a plan before exploration activity commences. Listed below are 

some of the reasons that ERT has submitted this proposal to MMS: 

• leaseholders have a legal right to pursue exploration for and development and 

production of hydrocarbon resources; 

• leaseholders are obligated via lease terms to diligently develop the resources; and 

• a lease term is limited to 10 years and failure to identify and develop resources could 

lead to loss of the sunk costs to acquire the lease, as well as yearly rentals to maintain 

access to the lease. 

1.3. DESCRIPTION OF THE PROPOSED ACTION

1.3.1. Proposed Action 

Energy Resource Technology, Inc. submitted a Supplemental DOCD to MMS on November 15, 

2007. ERT subsequently provided additional information regarding the plan that allowed MMS to 

determine it to be complete. In its DOCD, ERT proposes to drill and complete two new wells in Green 

Canyon Block 236 (OCS-G 15562) and four new wells in Green Canyon Block 237 (OCS-G 15563), 

install a subsea manifold, clear the location and install an FPU in Green Canyon Block 237, and 

commence production from Green Canyon Blocks 236 and 237 (ERT, 2007). 

Measured liquid hydrocarbons from Green Canyon Blocks 236 and 237 would be brought to the FPU 

in Green Canyon Block 237, the Helix Producer 1 (HP1) platform, where it would be transported via 

Enterprise Field Services’ 12-inch pipeline (Segment No. 12780) that connects to Shell Offshore Inc.’s 

Green Canyon Block 19 A platform for ultimate delivery to shore via Operations System No. 29.5 and/or 

Operations System No. 36.5. The Measured gas will depart the Green Canyon Block 237 HP1 platform 

via ANR Central Gulf Gathering Company, Inc.’s 20-inch pipeline (Segment No. 12749) that connects to 

Eugene Island Area Block 371 A platform for ultimate delivery to shore via Operations System No. 24.0. 

ERT will use a typical dynamically positioned (DP) semisubmersible drilling rig for the drilling and 

completion operations of the proposed wells. 

Associated Action and Activities 

Effective August 23, 2006, ERT was designated operator of Leases OCS-G 15562, 15563, 16727, and 

26302 for Green Canyon Blocks 236, 237, 282, and 238, respectively. ERT previously submitted to 

MMS application(s) to install 19 lease-term pipelines. ERT plans to reestablish production from the 

former Typhoon and Boris Fields. The Typhoon tension-leg platform (TLP), flowlines, and umbilicals 

were destroyed and severed by Hurricane Rita in September 2005 and will be replaced with similar 

components to reconnect the wells to a subsea manifold which would be connected to the DP floating 

production unit (Helix Producer 1). Thirteen of the lease-term pipelines would be installed initially to 
10 

produce the existing five wells in Green Canyon Blocks 237 and 282 (Green Canyon Block 237, Wells 

#001, #003, and #004 (Typhoon Field); Green Canyon Block 282, Wells #001 and #002 (Boris Field)) 

and a sixth well adjacent to the Boris Field, Green Canyon 238, Well #001 (Little Burn), which is not part 

of this proposed action. Those 13 pipelines would later be connected, and production would commence 

from the previously-mentioned existing five wells in Green Canyon Blocks 237 and 282 (ERT, 2007). 

This is part of ERT’s intention to reestablish production from five of the six wells that were being 

produced through the Typhoon TLP. 

1.3.2. Background 

Green Canyon Blocks 236 and 237 are located approximately 91 mi (146 km) southward from the 

nearest shoreline in Louisiana (i.e., Isle Dernieres, Terrebonne Parish) and approximately 105 mi (169 

km) from the supply base at Port Fourchon in Lafourche Parish, Louisiana (Figure 6). 

Figure 1 shows the location of Green Canyon Blocks 236 and 237 and the distance to the nearest 

shoreline from those blocks and the nearest shoreline from Grid 9. Table 1-1 shows the location data for 

the FPU, the six proposed wells, and the disconnectable transfer system (DTS) in ERT’s DOCD. 

Table 1-1 

 

Surface Locations of the Proposed Wells, Floating Production Unit, Disconnectable Transfer 

System, and Pipeline End Manifold 

Location of Activity Well Surface Location Water Depth 

Install Helix Producer 1 in GC 237 6,908′ FNL; 2,885′ FWL 

X=2,252,169.59′ ; Y=10,067,331.95′ 2,085′

Drill and complete GC 236 Well A 4,109′ FNL; 4,275′ FEL 

X=2,245,005′ ; Y=10,070,131′ 1,790′

Drill and complete GC 237 Well A 7,191′ FNL; 4,344′ FWL 

X=2,253,624′ ; Y=10,067,049′ 2,050′

Drill and complete GC 236 Well B 1,674′ FNL; 5,617′ FWL 

X=2,239,057′ ; Y=10,072,566′ 1,630′

Drill and complete GC 237 Well B 1,991′ FSL; 2,442′ FWL 

X=2,251,722′ ; Y=10,060,391′ 2,405′

Drill and complete GC 237 Well C 5,112′ FSL; 3,293′ FWL 

X=2,252,573′ ; Y=10,063,512′ 2,235′

Drill and complete GC 237 Well D 3,978′ FSL; 2,633′ FEL 

X=2,262,487′ ; Y=10,062,378′ 2,335′

Install Pipeline End Manifold in GC 237 3,300′ FSL; 6,500′ FWL 

X=2,265,668.27′ ; Y=10,061,708.83′ 2,360′

Install DTS in GC 237 6,908.05′ FNL; 2,885.59′ FWL 

X=2,252,165.59′ ; Y=10,067,331.95′ 2,085′

FEL = from the east block line, FNL = from the north block line, FSL = from the south block line, 

FWL = from the west block line, GC = Green Canyon. 

1.3.3. Schedule of Activities 

The drilling, completion, and installation program for the six wells and FPU proposed in the DOCD is 

scheduled to begin on October 1, 2008, with an estimated completion date of May 2013. The planned 

duration of drilling for the proposed action, i.e., to drill, complete, and produce the six new wells, is 

approximately 60 days (approximately 8 weeks) for each new well. Installation a lease-term pipeline(s) 
11 

segment(s) to commence production from each new well should take from 10 to 15 days. ERT reports 

that it will produce from the six new wells and will restore production and produce from the five existing 

wells for a duration of five years. ERT provided the schedule shown in Table 1-2. 

Table 1-2 

 

Schedule for Pipelaying, Drilling, Completion, and Production from Green Canyon Blocks 236 and 237 

Activity Estimated Start 

Date 

Estimated End 

Date 

Days 

Duration 

Install 13 lease-term pipelines in GC 236 and 237 02/01/08 03/21/08 50 days 

Hookup and commence production from existing wells 

in GC 237 and 282 09/01/08 09/01/13 5 years 

Drill and complete GC 237, Well A 10/01/08 11/29/08 60 days 

Drill and complete GC 237, Well B 12/02/08 01/30/09 60 days 

Install 2 lease-term pipelines 06/01/09 06/15/09 15 days 

Hookup and produce GC 237, Wells A and B 07/01/09 07/01/14 5 years 

Drill and complete GC 236, Well A 03/01/10 04/29/10 60 days 

Install 1 lease-term pipeline 05/01/10 05/10/10 10 days 

Hookup and produce GC 236, Well A 05/20/10 05/20/15 5 years 

Drill and complete GC 236, Well B 03/01/11 04/29/11 60 days 

Install 1 lease-term pipeline 05/01/11 05/10/11 10 days 

Hookup and produce GC 236, Well B 05/20/11 05/20/16 5 years 

Drill and complete GC 237, Well C 03/01/12 04/29/12 60 days 

Install 1 lease-term pipeline 05/01/12 05/10/12 10 days 

Hookup and produce GC 237, Well C 05/20/12 05/20/17 5 years 

Drill and complete GC 237, Well D 03/01/13 04/29/13 60 days 

Install 1 lease-term pipeline 05/01/13 05/10/13 10 days 

Hookup and produce GC 237, Well D 05/20/13 05/20/18 5 years 

GC = Green Canyon. 

1.3.4. Equipment and Drilling System 

ERT proposes to use a DP semisubmersible to drill the six new wells in Green Canyon Blocks 236 

and 237. The specifications of the rig chosen by ERT for the proposed action would be made a part of the 

Application for Permit to Drill. 

1.3.5. Support Facilities 

Supply and crewboats and aircraft (helicopter) facilities to support the proposed action are located in 

Port Fourchon in Lafourche Parish, Louisiana, 105 mi (169 km) north-northeast of the project location 

(Figure 6). Existing onshore base facilities located in Port Fourchon, Louisiana, will be used as the 

debarkation point for equipment, supplies, and crews. ERT does not expect any shore base construction 

or expansion in association with this proposed operation. 
12 

1.3.6. Transportation Operations 

Personal vehicles would be the main means of transportation to carry rig personnel from permanent or 

temporary residences to the Port Fourchon shore base. Personnel will then be transported to the drilling 

rig by the crewboat or helicopter. Supply boats will transport bulk supplies. The most practical, direct 

route permitted by the weather and traffic conditions would be used. The transportation route by service 

vessel is approximately 105 mi (169 km) to Green Canyon Blocks 236 and 237. The type of support 

vessels and travel frequency per week during drilling and completion operations are shown in Table 1-3. 

Table 1-3 

 

Support Vessel and Frequency 

Support Vessel Trips/Week Maximum Number 

in Area at Any Time 

Crewboats–personnel and supplies 2 1 

Supply boats–bulk supplies and casing 2 1 

Helicopter–personnel and small supplies 3 1 

1.3.7. New and Unusual Technology 

ERT proposes to use a disconnectable transfer system (DTS) for the proposed development of the 

Phoenix Field. The DTS allows disconnection from the flowlines, pipelines, and umbilicals. The riser 

system, which will be buoyed by six mooring lines, will enable the ship to disconnect and seek shelter 

from severe weather and during conditions when position cannot be maintained. The mooring lines do 

not provide any station-keeping service. 

1.3.8. Impacts from Potential Geological Hazards 

The MMS approved ERT’s request to use 3D exploration data for the shallow hazards assessment for 

Wells A and B in Green Canyon Block 237 on July 10, 2007, and for Wells A and B in Green Canyon 

Block 236 and Wells C and D in Green Canyon Block 237 on September 21, 2007. The MMS has 

received adequate, remotely operated vehicle (ROV) survey coverage for Grid 9; therefore, ERT is not 

required to conduct ROV surveys for the proposed operations, except during pre-spudding and postdrilling operations. 

Key seafloor hazards that may affect proposed activities include steep slopes, debris from Hurricane 

Rita in September 2005, faults, shallow water flow, and shallow gas. Slopes at the proposed wells and 

FPU sites are in a southward direction and range from 1.2° to 2.5°. Debris from the Typhoon TLP, its 

associated flowlines, and umbilicals would be cleared from the seafloor location of the six proposed wells 

and would not be closer than 845 ft (257 m) to any proposed well (Green Canyon Block 236, Well A). A 

fault scarp exists as close as 610 ft (186 m) to Green Canyon Block 236, Well A and 700 ft (213 m) 

northeast of Green Canyon Block 236, Well B. No high negative or high positive amplitude anomalies 

associated with fluid expulsion or mounded carbonates representing potential chemosynthetic 

communities were noted within a 1,500-ft (457-m) radius of the proposed well sites. One mound is found 

1,554 ft (474 m) to the northwest of Green Canyon Block 236, Well B and should be avoided. Green 

Canyon Block 236 is not classified by MMS as a “shallow-water, up flow area,” although Green Canyon 

Block 237 is. Shallow water flows occur when sands lie below a seal, which prevents dewatering and 

compaction, and in unconsolidated and overpressured sands. The pressure rises with overburden and 

presents a potential hazard for drilling. Shallow gas potential also exists in the Grid 9 area. A moderate 

to high amplitude anomaly was noted 4,488 ft (1,368 m) below sea-level (BSL) (Green Canyon Block 

236, Well A). Setting the first casing string above the anomaly at this wellsite is recommended. 

1.4. OFFSHORE DISCHARGES AND WASTE DISPOSAL

The discharge of wastes into offshore waters is regulated by the U.S. Environmental Protection 

Agency (USEPA) under the authority of the Clean Water Act. No wastes generated during oil and gas 
13 

operations can be discharged overboard unless they meet the standards required within a National 

Pollution Discharge Elimination System (NPDES) permit. All of the waste types generated from the 

proposed exploration activities for the Phoenix Project will be either (1) discharged overboard in 

compliance with NPDES requirements or (2) transported to shore for disposal in permitted or licensed 

commercial facilities or for recycling. The wastes for overboard discharge are summarized in Table 1-4. 

Table 1-4 

 

Projected Ocean Discharges from the Phoenix Project 

Type of Waste Total Amount Discharged Discharge Rate Discharge Method 

Spent Drilling Fluids 2,500/well 220 bbl/hour Discharged at the surface. 

Synthetic-based Fluids NA NA Recycle and discharged at the surface. 

Deck Drainage 0-365 bbl/yr 

(dependent upon rainfall) 

1 bbl/day Treated to remove oil and grease. 

Discharged overboard. 

Produced Water 250,000 bbl/yr 1,000 bbl/day Pipe to a well on lease, inject to 

downhole/Wemco discharge overboard. 

Wastes generated during the development and production activities of the Phoenix Project consist of 

(1) drill fluids; (2) drill cuttings (water-based fluids (WBF); (3) deck drainage; (4) sanitary and domestic 

wastes; (5) uncontaminated seawater used for cooling, desalinization, and ballast; (6) excess cement, (7) 

well treatment, workover, or completion fluids; (8) bilge water; (9) chemically treated seawater or 

freshwater; (10) used oil; and (11) solid trash and debris. Well treatment, completion, and workover 

fluids would be collected in a separator. Aqueous fluids would be routed to the water treatment system 

for discharge. Nonaqueous fluids would be collected in drums or the slop tank of a supply vessel to be 

transported to shore for disposal. 

Routine sanitary and domestic wastes necessarily arise from people working offshore on drilling rigs, 

production platforms, and support vessels. Estimates of the amounts of sanitary and domestic wastes 

discharged from associated service-vessel operations were not provided by ERT but are generally 

estimated to be 60 gallons (gal)/person/day (NERBC, 1976). 

Deck drainage effluent is primarily rainwater containing residual oil and grease from equipment 

washwater and rainwater. Overboard discharge of deck drainage is governed by the NPDES permit 

requirement for no visible oil sheen. A maximum for deck drainage during daily operation is estimated 

by MMS to be 3,000 barrels (bbl) per month. 

1.5. POTENTIAL IMPACT-PRODUCING FACTORS

Physical Disturbances to the Seafloor 

Physical disturbance of the seafloor will occur during installation, operation, and decommissioning. 

Seafloor impacts will result from (1) pipeline installation; (2) the installation of subsea production 

equipment including well trees, manifolds, flowline sleds, etc.; (3) and the installation of flowlines and 

umbilicals. The FPU will be kept in place via a DP2 dynamic positioning system. The riser system will 

enable the ship to disconnect and seek shelter from severe weather and during conditions when position 

cannot be maintained. The risers are connected to a buoy that will sink approximately 45 m (148 ft) when 

disconnected. The buoy is moored via six anchor chains, each 3,000 ft (914 m) long, which serve to keep 

the buoy in place. The mooring lines do not provide any station-keeping service. 

Subsea production equipment is assumed to include 1 FPU, 1 manifold, and 19 lease-term pipelines. 

The installation and eventual decommissioning of all subsea production equipment will directly disturb 

the seafloor. 

The 19 lease-term pipelines will be installed by a DP pipelaying barge. Because a DP pipelaying 

barge will be used for the lease-term pipelines, there will be no anchoring along the pipeline route. Since 

the water depth is greater than 200 ft (61 m) for the entire route, burial is not required. Therefore, the area 

affected by pipelaying is limited to the seafloor immediately beneath the pipe. 
14 

Effluent Discharges 

Effluent discharges will include discharges from vessels involved in facility installation, discharges 

during drilling and completion operations, and discharges from support vessels. Estimated waste 

discharges are quantified in Chapter 1.4. 

Air Pollutant Emissions 

Air pollution emissions occur primarily during installation and operation due to combustion of diesel 

fuel and natural gas by generators, vessel engines, and equipment. Flaring is another source of air 

pollution emissions. Air emissions from the proposed activity are addressed in Chapter 3.1.2. 

Presence of Structures 

The presence of offshore structures, including noise and lights, can have impacts on marine life, 

including fishes, marine mammals, turtles, and birds. It is well known that offshore structures serve as 

artificial reefs (Reggio, 1987; LGL Ecological Research Associates, Inc. and Science Applications 

International Corporation, 1998). In addition, offshore drilling and production activities produce a broad 

array of sounds at frequencies and intensities that may be detected by marine mammals and sea turtles. 

Brightly lit offshore platforms may attract sea turtle hatchlings, which could be subject to increased 

predation by birds and fishes that are also attracted to offshore structures. 

Vessel and Helicopter Traffic 

Vessels will travel back and forth between the DP semisubmersible and FPU and the shore base in 

Port Fourchon, Louisiana. Helicopters will travel back and forth from the heliport in Port Fourchon, 

Louisiana. The boats will normally move to the project area via the most direct route. The helicopter will 

be used for transporting personnel and small supplies and will normally take the most direct route of 

travel between the shore base and the project area when air traffic and weather conditions permit. Vessel 

and helicopter traffic may startle or disturb birds, marine mammals, and turtles. There is also a small risk 

of a supply boat or crewboat striking a marine mammal or turtle. 

Trash and Debris 

Potential trash and debris sources include the DP semisubmersible and FPU, construction vessels, and 

transportation vessels. Ingestion of, or entanglement with, accidentally discarded debris can kill or injure 

marine mammals, turtles, and birds. 

Accidents (Oil Spills) 

A spill is unlikely and, historically, most spills from offshore operations have been small. The MMS 

(USDOI, MMS, 2007) used an average spill size of 5 bbl for small (<1,000 bbl) offshore spills. 

The worst-case discharge is a crude oil spill of 21,000 barrels of oil per day which is estimated to be 

the volume of oil that could be released as a result of a well blowout and the loss of all storage and 

pipelines connected to the FPU. Blowouts are rare and usually do not result in a spill. Since 1998, four 

blowouts in the GOM have resulted in oil spills, with the amount of oil spilled ranging from <1 bbl to 200 

bbl. There have been no spills ≥1,000 bbl from blowouts in the last 30 years (USDOI, MMS, 2003a). As 

a result of Hurricanes Katrina and Rita in 2005, there were a total of 125 spills of ≥1 bbl and 39 spills of 

≥50 bbl. 

Other potential spill sources during the life of this development project (5 years) would include a spill 

of liquid oil stored on the platform (approximately 1,850-bbl total storage capacity including flowlines on 

the facility), a spill of liquid oil stored on the semisubmersible rig (approximately 19,000 bbl total storage 

capacity), a spill of liquid oil stored on the associated vessels (capacity of the largest vessel is 2,000 bbl), 

or a spill from the associated oil flowlines or the export pipelines. 
15 

1.6. REGULATORY FRAMEWORK

Federal laws mandate the OCS leasing program and the environmental reviews for the actions 

proposed by operators that seek to explore and produce hydrocarbons from Federal waters. An 

explanation of applicable statutes and regulations that comprise the regulatory framework for OCS 

activity and this proposed action is contained in the Multisale EIS (USDOI, MMS, 2007) and is hereby 

incorporated by reference into this PEA. 

2. ALTERNATIVES CONSIDERED 

2.1. NONAPPROVAL OF THE PROPOSAL

If this alternative was selected, ERT would not be allowed to undertake the proposed activities. This 

alternative could prevent the exploration for hydrocarbons and could result in the potential loss of royalty 

income for the citizens of the United States. Considering this outcome and that minimal impacts are 

anticipated, this alternative was not selected for further analysis. 

2.2. APPROVAL WITH EXISTING MITIGATION

The MMS’s lease stipulations, OCS Operating Regulations, Notices to Lessees and Operators 

(NTL’s), and other regulations and laws were identified throughout this environmental assessment as 

existing mitigation to minimize potential environmental effects associated with the proposed action. 

Since additional mitigations were identified to avoid or mitigate potential impacts with the proposed 

action, this alternative was not selected. 

2.3. APPROVAL WITH EXISTING AND/OR ADDED MITIGATION

The MMS’s lease stipulations, OCS Operating Regulations, NTL’s, and other regulations and laws 

were identified throughout this environmental assessment as existing mitigation to minimize potential 

environmental effects associated with the proposed action. Approval of the proposal with existing and 

additional mitigation is the selected alternative. The following additional mitigation has been identified. 

Mitigation 8.03 (Advisory)—H2S Absent 

The area in which the proposed drilling operations are to be conducted is hereby 

classified as “H2S absent,” in accordance with 30 CFR 250.417(c). The location and 

depths of the planned wells are not expected to encounter an H2S hazard. An H2S 

Contingency Plan is not required to be submitted and approved by the MMS prior to ERT 

conducting the proposed activities. (8.03)

3. DESCRIPTIONS AND IMPACT ANALYSES OF THE AFFECTED 

RESOURCES 

Chapter 3 describes the physical, biological, socioeconomic, and human resources in and adjacent to 

Grid 9, as well as within Green Canyon Blocks 236 and 237, that could be potentially affected by 

activities associated with the proposed Phoenix Project. The descriptions present environmental 

resources as they are now, thus providing baseline information for further analyses where potential 

impacts from future projects in Grid 9 are examined. Discussions in the Multisale EIS (USDOI, MMS, 

2007) are hereby incorporated by reference into this PEA and are briefly summarized throughout this 

PEA. 

3.1. PHYSICAL RESOURCES

Descriptions of the following components of the physical environment are contained in Appendix A 

of the Multisale EIS (USDOI, MMS, 2007): (1) geologic and geographic setting; (2) physical 
16 

oceanography; (3) meteorological conditions; and (4) existing OCS-related infrastructure. These 

discussions are hereby incorporated by reference into this PEA. 

Physical environments in the CPA are characterized in Chapter 3.1 of the Multisale EIS (USDOI, 

MMS, 2007) and are hereby incorporated by reference into this PEA. Summaries of these resources 

follow and include water quality and air quality. 

3.1.1. Water Quality 

3.1.1.1. Coastal Waters 

3.1.1.1.1. Description 

A detailed description of the coastal water quality can be found in Chapter 3.1.2.1. of the Multisale 

EIS and are hereby incorporated reference. The following information is a summary of the impact 

analysis incorporated from the Multisale EIS (USDOI, MMS, 2007). Coastal water quality along 

Louisiana and Texas is relevant to the Phoenix Project. The identified service base for the drilling, 

completion, and production activities from the new and existing wells in Green Canyon Blocks 236, 237, 

238, and 282 is located on the coast in Port Fourchon, Louisiana. Marine transportation to and from 

Green Canyon Blocks 236 and 237 would traverse coastal waters. 

Water quality in coastal waters of the northern GOM is highly influenced by season. For example, 

salinity in open water near the coast may vary between 29 and 32 parts per thousand (ppt) during fall and 

winter but decline to 20 ppt during spring and summer due to increased runoff (USDOI, MMS, 2000a). 

Temperature, dissolved oxygen, and nutrient concentrations also vary seasonally. 

Gulf Coast water quality was given a fair rating in the National Coastal Condition Report II (USEPA, 

2004). 

Population growth in coastal areas can result in a decline in water quality. Urban runoff is the leading 

source of contaminants that impair coastal water quality. 

Vessels from the shipping and fishing industries, as well as recreational boaters, add contaminants to 

coastal water in the form of bilge water, liquid and solid waste, spills, and chemicals leached from 

antifouling paints. Many millions of cubic feet of sediments are moved each year in coastal areas as a 

result of channelization, dredging, spoil disposal, and other hydromodifications. Water quality may be 

affected by these activities because they can lead to saltwater intrusion, increased turbidity, and the 

release of contaminants. 

3.1.1.1.2. Impact Analysis 

Sources that originate upriver from the Mississippi River Delta, as well as coastal sources, contribute 

to water quality degradation in nearshore and offshore environments of the GOM. These sources can be 

broadly characterized as industrial, agricultural, or municipal and point or nonpoint sources. 

A discussion of impacts to coastal water quality from OCS activity is provided in Chapters 4.1.3.4, 

4.2.1.1.2, and 4.2.2.1.2 of the Multisale EIS (USDOI, MMS, 2007) and is hereby incorporated by 

reference into this PEA. 

The impact-producing factors associated with drilling, completion, and production of the Phoenix 

Project in Green Canyon that could affect coastal water quality include (1) effluents from onshore support 

bases and OCS service vessels, such as sanitary and domestic wastes; (2) turbidity increases from vessel 

traffic; and (3) accidental spills of crude oil, diesel fuel, chemicals associated with production, or other 

materials from vessels in coastal waters. Water-based drilling muds and cuttings discharges, and 

produced-water discharges are impact-producing factors that originate and are discharged at the Phoenix 

Project, which is located approximately 91 mi (147 km) from the Louisiana coast and over 100 mi 

(160 km) from the Texas and Mississippi coasts. The discharges are regulated by USEPA and will not 

impact coastal waters. 

Domestic and sanitary waste would be discharged from support vessels after the required treatment. 

The effects on coastal waters from the Phoenix Project would primarily occur in heavy traffic areas such 

as navigation corridors and turning basins at Port Fourchon, Louisiana, which is the onshore support base. 

Service vessels that use navigation channels, turning basins, shallow harbors, and docking facilities 

could cause increases in water turbidity from mud that is resuspended by propeller wash. Dredging and 

spoil dumping carried out to maintain, deepen, or straighten navigation channels could also increase the 
17 

turbidity of coastal waters. Actions specifically attributed to vessels supporting the Phoenix Project 

would have an insignificant impact. 

The Phoenix Project is located approximately 91 mi (147 km) from the nearest Louisiana coastline. 

The distance of this project and the Green Canyon Blocks 236 and 237 infrastructure from coastal waters 

introduces lengthy spill travel times and tremendous dilution factors for any accidental spills of crude oil, 

diesel fuel, or other materials. Spills that affect coastal waters would tend to originate from pipelines 

leaks or severance or from vessels in transit to or from the coastal area. Spills that may occur in Green 

Canyon Blocks 236 and 237 present an extremely small likelihood of affecting coastal water resources. If 

a large spill (≥1,000 bbl) were to occur at the surface or originate from a well blowout, the oil would form 

a surface slick. Response efforts can recover or disperse some of the slick, and high surf could contribute 

to its break up while at sea. Weathering and evaporation of volatile organics can degrade a slick while at 

sea. Slicks existing for 10 days or more have a small chance to wash ashore. 

Some wastes not permitted for offshore disposal are brought ashore for disposal or recycling and can 

present spill hazards if not handled properly. Although not all these waste types will be generated by the 

developmental drilling, completion, and production from the Green Canyon Blocks 236 and 237 wells 

covered by this DOCD, exploration and production waste (E&P waste) can include oil-based drilling 

fluids and drill cuttings, liquid wastes (“fracing” fluids, i.e., fluids forced into formations to fracture, 

dissolve cement, or prop open pore throats, emulsifiers, workover fluids, mud additives, etc.), and 

possibly well test solids and produced sand and are also transported across coastal waters to shore. These 

wastes are taken to transfer stations and on to State-regulated disposal locations in Texas and Louisiana. 

Conclusion 

No significant long-term impacts on coastal water quality would be expected from the proposed 

Phoenix Project. Because the proposed action would use existing onshore support bases, only the 

discharges from these support bases or service vessels would result in effects to coastal waters. The 

contribution by the proposed action to the level of these effects is expected to be very minor, transient, 

and not contribute significantly to the decline in coastal water quality. Spilled oil originating in coastal 

waters and attributable to the Phoenix Project would not be ≥1,000 bbl and is expected to be substantially 

recovered while still at sea. 

3.1.1.1.3. Cumulative Analysis 

Cumulative impacts on water quality include sources of pollutants that affect both coastal and 

offshore settings. Human sources in coastal waters include effluents, wastes, or surface runoff from 

varied urban, rural, and industrial sources. These sources include the following: (1) petrochemical 

industry (inclusive of OCS development and processing); (2) agriculture and animal processing; (3) 

agricultural and urban runoff; (4) municipal and recreational sewerage treatment; (5) marinas; (6) 

commercial fishing; (7) maritime shipping and cruise ships; (8) hydromodification activities; (9) wood 

processing, pulp, and paper mills; (10) recreational boating and fishing; (11) manufacturing activities; 

(12) accidental spills of oil, diesel fuel, or other material; and (13) atmospheric deposition of airborne 

contaminants onto the sea. Contaminants entering coastal waters can also be transported to offshore 

marine waters. 

Human sources in offshore waters include effluents and discharges from fixed (e.g., mobile offshore 

drilling units (MODU’s), semisubmersibles, and production platforms) and mobile sources (i.e., vessels 

of all types). Each fixed or mobile source has routine and permitted effluents and discharges. Fixed 

platforms and MODU’s discharge (1) water-based muds and cuttings; (2) cuttings wetted with syntheticbased mud (SBM); (3) small quantities of wellbore cement and treatment, completion, and workover 

chemicals; (4) domestic and sanitary discharges; (5) produced water; (6) bilge, ballast, cooling, and 

desalinization unit water; and (7) deck wash. 

Vessels such as OCS service boats and crewboats, freighters, tankers, barges, fishing boats, and cruise 

ships discharge (1) bilge, ballast, and cooling water; (2) domestic and sanitary discharges; and (3) deck 

wash. Both fixed and mobile sources can accidentally spill oil, diesel fuel, or other material, and trash 

and debris can be lost overboard despite handling requirements. 

Worldwide, natural seeps from geologic formations release 4,200,000 bbl (1.8 x 108

 gal) of oil into 

the oceans each year (NRC, 2003). Natural hydrocarbon seeps are the most significant source of oil 

entering Gulf waters. Relatively recent studies have suggested that seepage rates in the GOM are much 
18 

higher than earlier estimates (NRC, 2003). Mitchell (2000) estimated that 500,000 bbl/yr of oil seeped 

into northern GOM waters (U.S. territorial waters); a figure NRC doubled to estimate seepage rates for 

the entire GOM. In the same range, if apportioned to the GOM, would be a estimate by MMS (USDOI, 

MMS, 2003b), which concluded that 1,700 bbl/day are released into all U.S. territorial waters each day by 

natural seeps (620,000 bbl/yr). The NRC (2003) estimated that an average of 980,000 bbl of oil enters the 

entire GOM each year from natural seeps (with a range of 560,000 to 1,400,000 bbl). This average 

amount is four times the volume of the 1989 Exxon Valdez spill (USDOC, NOAA, 1992) every year. 

The NRC (2003) reports the annual contribution of oil in marine waters of North America (U.S. and 

Canada) from various human activities and natural sources. The NRC (2003) provided a best estimate 

that 1,820,000 bbl of petroleum enters North American marine waters (U.S. and Canada) each year. The 

majority of this amount is from natural seeps; approximately 1,120,000 bbl or 62 percent. The NRC 

(2003) has shown that the largest fraction of oil entering the water from all sources relates to the 

consumption of petroleum (33%) and that only 5 percent is related to the production or transportation of 

oil (including refining). Subtracting out the amount contributed by natural seeps, nearly 85 percent of the 

627,700 bbl of oil entering North American marine waters each year from human activities comes from 

the following sources, in relative order: (1) land-based runoff and polluted rivers; (2) recreational boats 

and jet skis, particularly those with 2-cycle engines; (3) atmospheric deposition; and (4) jettisoned aircraft 

fuel (NRC, 2003). Approximately 9 percent of the total attributable to human activity comes from 

transportation, pipeline, or refining activity (NRC, 2003), and 3 percent comes from oil and gas 

exploration and production (NRC, 2003). 

No irreversible or irretrievable impacts to the marine environment on a broad oceanic scale are caused 

by either natural seeps or accidental spills (NRC, 2003). Natural seeps have released oil into the GOM 

and the oceans of the world in all types of coastal and marine environments for millennia. Natural marine 

systems can accommodate rather substantial quantities of oil in the sea, apparently without much 

noticeable impact. 

The incremental contribution of the proposed action’s impacts to the cumulative impact on coastal 

water quality is negligible and likely undetectable among the other cumulative impacts. 

3.1.1.2. Offshore Waters 

3.1.1.2.1. Description 

The water offshore of the Gulf coasts can be divided into two regions: the continental shelf and the 

slope (<1,000 ft or 305 m) and deep water (>1,000 ft or 305 m). The continental shelf off the modern 

Mississippi River Delta is narrow because of the outbuilding of sediment from the river onto the shelf. 

To the east and west the shelf broadens. Waters on the continental shelf and slope are heavily influenced 

by the Mississippi and Atchafalaya Rivers, the primary sources of freshwater, sediment, and pollutants 

from a huge drainage basin encompassing 55 percent of the continental U.S. (Murray, 1998). Lower 

salinities are characteristic nearshore where freshwater from the rivers mix with Gulf waters. While the 

average discharge from the Mississippi River exceeds the input of all other rivers along the TexasLouisiana coast by a factor of 10, during low-flow periods the Mississippi River can have a flow less than 

all these rivers combined (Nowlin et al., 1998). 

A zone of hypoxia on the Louisiana-Texas shelf is one of the largest areas of low oxygen in the 

world’s coastal waters (Murray, 1998). Hypoxic conditions are caused by a seasonal stratified water 

column. The less dense and low-salinity water from the Mississippi River “floats” on top of denser, more 

saline water and creates a stratified water column. High nutrient loads in the river water enhance algae 

production and increase the amount of decaying organic matter accumulating at the sea bottom. Decay 

depletes oxygen in bottom waters to the point of hypoxia (<2 mg/l dissolved oxygen) while the oxygen 

content of near-surface water is at or near to saturation. The hypoxic oxygen levels are low enough to 

affect the abundance, health, and vitality of soft-bottom invertebrate faunas and bottom-dwelling fish. 

Under severe or prolonged conditions it can kill bottom fauna. 

The presence or extent of a nepheloid layer at the sea bottom affects water quality on the shelf and 

slope. A nepheloid layer is a zone of suspended clay-sized particles that may play a role in transporting 

fine-grained sediment and contaminants from nearshore to offshore waters. The nepheloid layer can be 

thin and near bottom or very thick, depending on factors such as water depth, depth of water-column 

mixing, season, and sediment input. The shelf area is characterized by a bottom nepheloid layer and 

surface lenses of suspended particulates that originate from river outflow. Freshwater from the 
19 

Mississippi/Atchafalaya River systems may carry trace amounts of organic pollutants, including 

polynuclear aromatic hydrocarbons (PAH); herbicides such as atrazine, chlorinated pesticides, and 

polychlorinated biphenyls (PCB’s); and trace inorganic (metals) pollutants. 

The concentration of hydrocarbons in slope sediments (except in seep areas) is lower than 

concentrations reported for shelf and coastal sediments (Gallaway et al., 2003). In general, the CPA has 

higher levels of hydrocarbons in sediment, particularly those from terrestrial sources, than the WPA and 

Eastern Planning Area (EPA) (Gallaway and Kennicutt, 1988). Total organic carbon is also highest in the 

CPA. Hydrocarbons in sediments have been determined to influence biological communities of the Gulf 

slope, even when present in trace amounts (Gallaway and Kennicutt, 1988). 

Hydrocarbon seeps are extensive throughout the continental slope and contribute hydrocarbons to the 

surface sediments and water column, especially in the CPA (Sassen et al., 1993a and b). Natural 

hydrocarbon seepage is considered to be a major source of petroleum into Gulf slope waters (Kennicutt et 

al., 1987; Gallaway et al., 2003), and the NRC (2003) considers seeps to be the predominant source. 

MacDonald et al. (1993) observed 63 individual seeps using remote-sensing and submarine observations. 

The NRC (2003) reported that estimates of the total volume of seeping oil in the GOM vary widely from 

28,000 bbl/yr (MacDonald, 1998) to a range of between 280,000 and 700,000 bbl/yr (Mitchell et al., 

1999). The NRC’s own best estimate is an annual input of 980,000 bbl/yr for the entire Gulf (NRC, 

2003), which is four times the volume of the Exxon Valdez spill per year (estimated to have been 260,000 

bbl (NRC, 2003)). Clearly, natural seeps account for a large quantity of oil that enters Gulf waters each 

year from a phenomena occurring over geologic time scales. Seep oil is a natural component of Gulf 

water, and oil in the water is called a pollutant or contaminant only when introduced in large quantities in 

a small area over a short period of time. 

In addition to hydrocarbon seeps, other fluids leak from the underlying sediments into the bottom 

water along the slope. These fluids have been identified to have three origins: (1) seawater trapped 

during the settling of sediments; (2) brine from dissolution of underlying salt diapirs; and (3) deep-seated 

formation waters (Fu and Aharon, 1998; Aharon et al., 2001). 

Produced water (formation water) is the volumetrically largest waste stream from the oil and gas 

industry that enters Gulf waters. Produced water is commonly treated to separate free oil and is either 

injected back into the reservoir or discharged overboard according to NPDES permit limits (Chapter 1.4, 

Offshore Discharges and Waste Disposal). The NRC has estimated the quantity of oil in produced water 

entering the Gulf per year to be 473,000 bbl (NRC, 2003; Table D-8). 

Green Canyon Blocks 236 and 237 are entirely in deep water, for which limited information is 

available on water quality. Generally, the water quality in deep water could be considered significantly 

better than that of the coastal waters (USDOI, MMS, 2007). Water at depths >1,400 m (4,593 ft) is 

relatively homogeneous with respect to temperature, salinity, and oxygen (Nowlin, 1972; Pequegnat, 

1983; Gallaway et al., 1988). Offshore Texas, Louisiana, and Alabama show detectable levels of 

petroleum hydrocarbons, likely from natural seeps (USDOI, MMS, 1997 and 2000b). Pequegnat (1983) 

pointed out the importance of water-column mixing and flush time for the GOM. Oxygen in deep water 

must originate from the surface and be mixed into deep water by some mechanism, but the time for 

turnover or the mechanism by which oxygen replenishment takes place in the deep GOM is essentially 

unknown. 

Deepwater sediments, with the exception of barium concentrations in the vicinity of previous drilling, 

do not appear to contain elevated levels of metal contaminants (USDOI, MMS, 1997 and 2000b). 

Reported total hydrocarbons, including biogenic (e.g., from plankton and other biological sources) 

hydrocarbons, in sediments collected from the Gulf slope range from 5 to 86 ng/g (Kennicutt et al., 1987). 

Petroleum hydrocarbons, including aromatic hydrocarbons (<5 ppb), were present at all sites sampled. 

The MMS studied the effect of exploration and development at four drilling sites located in water 

depths greater than 1,000 m (3,280 ft) (CSA, 2006). The sampling design called for before and after 

exploratory or development drilling and captured the drilling-related changes that occur in sediments and 

sediment pore water. Samples were collected from near- and far-field locations in the interval between 

exploratory drilling and development drilling and again after development wells were drilled. The 

Garden Banks sample locations were about 70 mi (113 km) west of the Phoenix Project in similar water 

depths. Three exploratory wells had been drilled, and barite was elevated in nearly all near-field sample 

stations. Some concentrations of metals associated with barite were also elevated at near-field stations 

above far-field concentrations. Total PAH concentrations in the near-field sediments ranged from 194 to 
20 

3,470 ng/g following exploratory drilling and from 142 to 431 ng/g a year later and after the drilling of 

five development wells. 

3.1.1.2.2. Impact Analysis 

The impact-producing factors associated with proposed Phoenix Project and commencement of 

production in Green Canyon that could affect offshore water quality include (1) degradation of GOM 

offshore waters from coastal activity, runoff, and riverine inputs; (2) discharges during the drilling of 

wells; (3) discharges during production, (4) bottom disturbances related to the installation of the subsea 

manifold and placement of the new or replacement of the additional hurricane-damaged flowlines and 

umbilicals and accidental spills of crude oil, diesel fuel, chemicals or other materials from vessels in 

offshore waters. A discussion of impacts to offshore water quality from OCS activity is provided in 

Chapters 4.1.3.4, 4.2.1.1.2, and 4.2.2.1.2 of the Multisale EIS (USDOI, MMS, 2007) and is hereby 

incorporated by reference into this PEA. 

Operations 

Water depths in Green Canyon Blocks 236 and 237 range from 1,600 to 2,400 ft (488 to 732 m). 

These deep marine waters and environments would be most directly affected by the proposed Phoenix 

Project activities. Drilling activities will be conducted from a DP semisubmersible drilling rig. 

Production will be conducted from a dynamically positioned FPU with no sediment disturbance from 

moorings, anchors, or pipeline placement. Sediment disturbances will result from the replacement of the 

subsea flowlines, umbilicals and manifold. A range of effluents and wastes would be discharged 

overboard from the proposed Phoenix Project. Overboard discharges and wastes intended from the 

project are shown in the wastes and discharge tables (Tables A-1 and A-2, respectively). The types and 

discharge rates will be in accordance with USEPA NPDES General Permit GMG 290000 for USEPA 

Region 6, or an individual NPDES permit if one is secured by ERT and its partners. Wastes destined for 

onshore disposal or recycling pose no potential impacts to affected resources unless spilled. 

A total of six new development wells would be drilled. Water-based drilling fluid (WBF) would be 

used. The DOCD estimates the use of 10,000 bbl of WBF per well and the discharge of 2,500 bbl per 

well of water-based drilling mud containing barite per well. The MMS estimates about 2,000-3,000 bbl 

of WBF cuttings per well. Five existing wells would be put back on line. 

Sanitary and domestic waste would be produced on the semisubmersible at rates of 20 gal/person/day 

and 30 gal/person/day, respectively. These discharges are treated to meet USEPA discharge 

requirements. Discharge would occur daily. Water would be impacted by the introduction of suspended 

solids and biochemical oxygen demand (BOD) matter. Offshore waste and discharge tables for the 

Phoenix Project are included in Appendix A. 

Accidental Events 

The failure or disconnect of a riser system could result in the release of some or all of the fluid in the 

annuli. Riser system failures and disconnects, though not common, have occurred in the past (USDOI, 

MMS, 2000b and 2003c). 

No blowouts resulting in spills ≥1,000 bbl are projected as a result of drilling associated with the 

Phoenix Project based on historical trends in the GOM (Appendix B). Based upon historical spill rates 

and the anticipated volumes over the life of the Phoenix Project, it is projected that spills that occur from 

the Phoenix Project would be few (if any). 

Conclusion 

No significant long-term impacts on offshore water quality would be expected from the proposed 

Phoenix Project. Near-bottom water quality would be affected by increased turbidity and disturbed 

substrates during the period of drilling subsea production equipment placement. Any effects from the 

elevated turbidity would be short term, localized, and reversible. Small numbers of bottom-dwelling 

invertebrates may be killed or adversely impacted. 

Impacts on offshore water quality from the operational discharges that would be expected to result 

from the Phoenix Project are insignificant because of (1) existing environmental regulations, (2) great 
21 

water depth, (3) distance of the project from the coast, (4) spill transit times, and (5) dilution factors. An 

accidental oil spill would affect water quality at the surface (top few meters or feet of the water column). 

Operator-initiated activities to contain and clean up an oil spill would begin as soon as possible after an 

event. Small quantities of unrecovered oil would weather and largely biodegrade within 2 weeks. 

3.1.1.2.3. Cumulative Analysis 

The sources identified in Chapter 3.1.1 of the Multisale EIS (USDOI, MMS, 2007) contribute to 

cumulative water quality degradation in offshore waters. Spills of oil, diesel fuel, and other materials 

may occur from vessels transporting crude oil and petroleum products; from vessels involved in 

commercial fishing, freight, or passenger transport; and from OCS operations. Well blowouts can disturb 

the bottom, increase turbidity, and put oil into the sea. Should one of these blowouts occur, localized, 

short-term changes in water quality would be expected. Cumulative impacts would be negligible. 

Bottom-area disturbances resulting from non-OCS sources are not expected in Green Canyon Blocks 

236 and 237 water depths. Cumulative impacts are negligible. 

Daily operational discharges to offshore waters occur from vessels moving through Gulf waters and 

from MODU’s and production facilities (Chapters 3.1.1.1.2 and 3.1.1.2.2 of the Multisale EIS (USDOI, 

MMS, 2007)). The discharge of drilling fluid, cuttings, and produced water are the main effluents from 

oil and gas exploration, development, and production operations. The contaminant deposition and 

accumulation rate on the sea bottom from discharges is primarily dependent on the water depth and 

current strength. Sediment contaminants from OCS discharges may occur from several hundred to 

several thousand meters or feet from the discharge point depending on the volumes discharged. 

Biological responses to contaminant levels retained in bottom sediments are not expected to be detectable 

beyond a couple hundred meters or feet, and toxic effects to the benthos would be localized, limited to 

within a hundred meters or feet of the discharge, and of a relatively small magnitude. Toxic effects 

beyond 100 m (328 ft) should be controlled through the USEPA’s NPDES permit requirements. 

Well blowouts can resuspend fine-grained sediment in the water to increase turbidity. The rapid 

accumulation of sediment (or cuttings if well drilling is part of the development project) on the sea 

bottom that are thicker than 30 cm (1 ft) would be lethal for all sessile and most motile invertebrates 

(Frey, 1975; Basan et al., 1978; Ekdale et al., 1984). An accumulation rate of this type would not be 

expected in most deepwater development projects, and most soft-bottom, motile invertebrates would have 

a chance to react and move. Diluted and discharged slowly over large areas, these wastes contribute in a 

very small way to the degradation of offshore water quality. As a result, cumulative impacts are 

negligible. 

3.1.2. Air Quality 

3.1.2.1. Description 

Green Canyon Blocks 236 and 237 are located west of 87.5° W. longitude and hence fall under 

MMS’s jurisdiction for enforcement of the Clean Air Act. The air over the OCS water is not classified, 

but it is presumed to be better than the National Ambient Air Quality Standards (NAAQS) for all criteria 

pollutants. The Phoenix Project in Green Canyon Blocks 236 and 237 is located approximately 91 mi 

(145 km) south of Terrebonne Parish, Louisiana, an area that is in attainment of the NAAQS for CO, 

NOx, SOx, and PM and that, for prevention of significant deterioration (PSD) purposes, is classified as a 

Class II area. 

The influence to onshore air quality is dependent upon meteorological conditions and air pollution 

emitted from operational activities. The pertinent meteorological conditions regarding air quality are the 

wind speed and direction, the atmospheric stability, and the mixing height (which govern the dispersion 

and transport of emissions). The typical synoptic wind flow for Green Canyon Blocks 236 and 237 are 

driven by the clockwise circulation around the Bermuda High, resulting in a prevailing southeasterly to 

southerly flow, which is conducive to transporting emissions toward shore. However, superimposed upon 

this synoptic circulation are smaller meso-scale wind flow patterns, such as the land/sea breeze 

phenomenon. In addition, there are other synoptic scale patterns that occur periodically, namely tropical 

cyclones, and mid-latitude frontal systems. Because of the routine occurrence of these various conditions, 

the winds blow from all directions in the area of concern (Florida A&M University, 1988). 
22 

3.1.2.2. Impact Analysis 

Air quality would be affected in the immediate vicinity of the drilling and completion operations, 

service vessels, and aircraft. The cumulative impact from emissions for this DOCD will not exceed 

MMS’s exemption levels. The drilling activities are not expected to significantly affect onshore air 

quality. The distance from Green Canyon Blocks 236 and 237 to any PSD Class I air quality area such as 

the Breton National Wildlife Refuge is >200 km (124 mi). Port Fourchon, Laforuche Parish, Louisiana, 

the location of the service base, is in attainment for ozone (USDOI, MMS, 2007). 

Air quality could be affected in the event of spilled oil. The volatile organic compounds (VOC), 

which would escape to the atmosphere from a surface slick, are precursors to photochemically produced 

ozone. A spike in VOC’s could contribute to a corresponding spike in ozone, especially if the release 

were to occur on a hot sunny day in a NO2-rich environment. The corresponding onshore area is in 

nonattainment for ozone. However, due to the distance from shore, the project is not expected to have 

any impacts on onshore air quality including nonattainment areas. If a fire occurs, particulate and 

combustible emissions will be released in addition to the VOC’s. 

Conclusion 

No significant long-term impacts on air quality would be expected from the proposed Phoenix 

Project. The air quality in the immediate vicinity of the proposed activities would be affected by the 

projected emissions. The distance between Green Canyon Blocks 236 and 237 and the shoreline 

introduces tremendous dilution factors for point-source emissions in Green Canyon Blocks 236 and 237. 

No special mitigation, monitoring, or reporting requirements apply to this project. 

3.1.2.3. Cumulative Analysis 

Cumulative impacts on air quality within the offshore area would come primarily from sources 

generated outside Green Canyon Blocks 236 and 237 and include emissions from industrial plants, power 

generation, and urban transportation. The location of Green Canyon Blocks 236 and 237 is far removed 

from coastal populations or industrial activity. The OCS activity that takes place in Green Canyon Blocks 

236 and 237 is >90 mi (144 km) from shore and would not affect the overall quality of air over the 

Louisiana coast. 

3.2 BIOLOGICAL RESOURCES

3.2.1. Sensitive Coastal Resources 

Sensitive coastal environmental resources in the Central Gulf are characterized in Chapter 3.2.1 of the 

Multisale EIS (USDOI, MMS, 2007) and are hereby incorporated by reference into this PEA. Summaries 

of these resources follow and include (1) coastal barrier beaches and associated dunes and (2) wetlands. 

The impact-producing factors associated with the proposed development and production of the 

Phoenix Project in Green Canyon Blocks 236 and 237 that could affect coastal barrier beaches and 

associated dunes, and wetlands include (1) oil spills from blowouts or vessel collisions, (2) chemical and 

drilling fluid spills, and (3) oil-spill response and cleanup. Of these, oil spills represent a high 

consequence and low-probability accidental event. Chapters 4.2.1.1.3 and 4.2.2.1.3 (Impacts on Sensitive 

Coastal Environments) of the Multisale EIS (USDOI, MMS, 2007) contain a discussion of impacts from 

OCS activity on coastal barrier beaches and associated dunes and wetlands and are hereby incorporated 

by reference into this PEA. 

No blowouts would be expected as a result of well completions, workovers, or hydrocarbon 

production associated with the proposed Phoenix Project, based on historical trends in the GOM (Table 

B-1). Spills that occur from development and production activity would be few (if any), volumetrically 

small, and be located near project activities in Green Canyon Blocks 236 and 237. 

Table B-4 indicates Gulfwide oil-spill occurrence rates. The statistics show that there have been 

numerous spills of >1 but <50 bbl but very few spills ≥1,000 bbl for all OCS operations per billion barrels 

of oil handled. A blowout is the only accident category that could yield a spill ≥1,000 bbl over the 5-year 

life cycle of the Phoenix Field production. The probability of a blowout is small, less than 1 in 100,000, 
23 

and the combined probability of a spill ≥1,000 bbl making landfall in Louisiana or adjacent states would 

be extremely small (<0.5%). 

Spills occurring in the deepwater environment of Grid 9 would not be large enough to enable them to 

persist long enough in the marine environment before weathering processes significantly degrade the spill 

before it makes landfall. The transport time would allow a slick to weather, dissolve, and disperse while 

still in the marine environment. If a spill occurs at sea, mechanical cleanup is assumed to collect up to 10 

percent of the spilled oil and approximately 30 percent is assumed to be chemically dispersed, further 

reducing the overall probability and severity of spills that may enter coastal waters and make landfall. 

Because landfall of spilled oil, diesel fuel, drilling fluids, or chemicals is highly unlikely from the 

proposed activities, the potential impacts from spill landfall (i.e., response and cleanup activities on 

coastal barrier beaches and associated dunes and wetlands) would not be expected to occur. 

Oil-spill response activity is governed by area contingency plans authorized by the Oil Pollution Act 

of 1990 and coordinated by the U.S. Coast Guard (USCG). These plans specify response procedures, 

priorities, and appropriate countermeasures for local coastal resources. The cleanup of slicks that come to 

rest in wetland areas or protected waters (0-1.5 m or 0-5 ft deep) may be performed using “john” boats, 

booms, anchors, and skimmers mounted on boats or shore vehicles. Oil-spill cleanup personnel in water 

shallower than about 1 m (3 ft) may simply wade through the water to complete their tasks. Trampling by 

foot traffic, swamp buggies, and cleanup equipment can cause damage to sensitive coastal resources by 

working oil more deeply into the sediments so that it is less available for dissolution, oxidation, or 

microbial degradation. 

The loss of sensitive coastal environments from subsidence due to fluid withdrawal, dredging to 

maintain channels, flood control projects, and channelization can occur (USDOI, MMS, 2007; Chapter 

4.5.3). Insofar as the oil and gas industry on the OCS is one of many industrialized uses of coastal 

waters, the incremental contribution of the proposed action to the cumulative impacts on sensitive coastal 

resources is expected to be very small. 

3.2.1.1. Coastal Barrier Beaches and Associated Dunes 

3.2.1.1.1. Description 

The description, physical location, and formative processes that create the various coastal beaches and 

barrier island complexes are described in Chapter 3.2.1.1 of the Multisale EIS (USDOI, MMS, 2007). A 

description of integrated shoreline environments, the barrier islands, and the dune zones that comprise and 

delineate the various vegetated habitats along these mainland and barrier beaches can also be found in 

Chapter 3.2.1.1 of the Multisale EIS (USDOI, MMS, 2007); therefore, the discussion that follows hereby 

incorporates by reference the Multisale EIS and briefly summarizes the pertinent features of these 

resources in relation to their ability to allow, minimize, or neutralize the impact-producing factors 

associated with the proposed action. In addition, the post-hurricane condition of these island and beach 

resources, along with their integral protective features, will be described. 

Each of the barriers is either high profile or low profile depending on the elevations and morphology 

of the island (Morton et al., 2004). The height and continuity of these elevations determine the ability of 

the barriers to withstand storm surge flooding and overwash. The Louisiana coastal barrier beaches and 

associated dunes that occur along this area of the GOM are typically composed of sandy beaches that are 

divided into several interrelated environments composed of a shore face, foreshore, and backshore. The 

Louisiana barrier island beaches are in constant flux as a result of the sediment source, composition, and 

the wave and wind climate in the vicinity of the islands. Those remaining Louisiana barrier islands 

located farther to the west are regressive in nature (island migration is more seaward), and the shorelines 

of these island formations are characterized by (1) wider and higher profiles, (2) well-vegetated dunes, 

and (3) few, if any, wash-over channels (USDOI, MMS, 2007). Thick accumulations of sand may form 

parallel ridges, such as those that typify the Chenier Plain of western coastal Louisiana. Both 

transgressive and regressive shorelines are important ecologically. Barrier islands, particularly vegetated 

ones with freshwater and/or saltwater pools, may serve as habitat for a wide variety of animal life, 

especially birds. In general, most of the Louisiana barrier island chain is moving landward, thereby 

increasing the vulnerability of the Louisiana coastline to storm surge along with the associated wetlands 

loss. 

Hurricane Katrina in August 2005 caused severe erosion and landloss for the coastal barrier islands of 

the deltaic plain. The eye of Hurricane Katrina passed directly over the 50-mi (80-km) Chandeleur Island 
24 

chain. Aerial surveys conducted by the U.S. Geological Survey on September 1, 2005, show that these 

islands were heavily damaged by the storm (USDOI, GS, 2005). Initial estimates suggest that Hurricane 

Katrina reduced the Chandeleur Islands by one-half of their pre-storm land area (USDOC, NOAA/NMFS, 

2007). Although barrier islands and shorelines have some capacity to regenerate over time, the process is 

very slow and often incomplete. With each passing storm, the size and resiliency of these areas can be 

diminished, especially when major storms occur within a short time period. Hurricane Katrina was the 

fifth hurricane to impact the Chandeleur Island chain in the past 8 years. The other storms were 

Hurricanes Georges (1998), Lili (2002), Ivan (2004), and Dennis (2005). 

Grand Isle was also heavily damaged by Hurricane Katrina. Although Hurricane Katrina made 

landfall more than 50 mi (80 km) to its east, Grand Isle received extremely high winds and a 12- to 20-ft 

(4- to 6-m) storm surge that caused tremendous structural damage to most of the island’s camps, homes, 

and businesses (Louisiana Sea Grant, 2005). Hurricane Rita in September 2005 severely impacted the 

shoreface and beach communities of Cameron Parish in southwest Louisiana. Some small towns in this 

area have no standing structures remaining. A storm surge approaching 20 ft (6 m) caused beach erosion 

and overwash that flattened coastal dunes, depositing sand and debris well into the backing marshes. 

Barrier beaches and dune environments are further characterized in Chapter 3.2.1.1 of the Multisale EIS 

(USDOI, MMS, 2007). 

In summary, the barrier islands from Texas to Florida (i.e., the WPA, CPA, and EPA) incurred some 

type of damage from the combination of Hurricanes Katrina and Rita and, in some cases, in combination 

with Hurricanes Wilma and Ivan as well. While Louisiana barrier islands incurred most of the damage, 

all of the areas experienced varying degrees of erosion, land and vegetation loss, loss in elevation or 

beach profile and, in some cases, movement toward shore as a result of the previous highly active 

hurricane season. The resulting changes in elevation and island profiles reduce the ability of these 

features to provide the pre-storm coastal protection to the mainland beaches and wetlands. While these 

barriers can rebuild to some extent naturally over time, it is the intent of both Federal and State coastal 

restoration projects, such as the Coastal Wetlands Planning, Protection, and Restoration Act, the 

Louisiana Coastal Restoration Program, and the Coastal Impact Assistance Program to assist in these 

barrier island restorations. 

3.2.1.1.2. Impact Analysis 

The impact-producing factors associated with the proposed action that could affect coastal barrier 

beaches and associated dunes include support for the construction from onshore facilities; vessel traffic; 

and oil spills from blowouts or vessel collisions, spill response, and cleanup. No nearshore pipeline 

emplacement or new pipeline corridors are needed as a result of this proposed action. The impactproducing factors described above are discussed in Chapter 4.1.1 of the Multisale EIS in (USDOI, MMS, 

2007) and are hereby incorporated by reference into this PEA. Site-specific analyses of potential impacts 

to resources are described in this Chapter. The subregional oil-spill response plan is discussed in 

Appendix B. 

It is assumed all offshore coastal spills would contact land and proximate resources. Most inshore 

spills resulting from the proposed action would occur from barge, pipeline, and storage tank accidents 

involving transfer operations, leaks, and pipeline breaks, which are remote from coastal barrier beaches. 

For a barge or pipeline accident in State or Federal offshore waters to affect a coastal barrier beach, the 

accident would need to occur on a coastal barrier beach or associated dune, or in the vicinity of a tidal 

inlet. 

During well and subset well installation there are expected to be slight increases in the number of 

vessel transits to and from support bases and fabrication yards, resulting in minor incremental impacts to 

channels and coastal erosion rates. Given the limited number of vessels required and the relatively short 

timeframe for each phase of installation activity, such impacts are short term and extremely localized. 

The significance of these incremental increases in impacts varies depending upon the location of the 

transport vessel destination, which in this case is Port Fourchon, Louisiana. 

Vessel traffic through channels and in close proximity to coastal barrier islands has been shown to 

move considerably more bottom sediment than tidal currents, thus increasing coastal and barrier island 

erosion rates. The incremental increases in channel and coastal erosion associated with increased vessel 

traffic can be expected to be more significant in those coastal barrier island or beach locations that are 

currently undergoing transgression. The erodability of some of the coastal barrier islands off of Louisiana 

and Mississippi has increased due to the hurricane-induced erosion and the removal or die off of the 
25 

wetland vegetation. However, given the level of other tanker and vessel traffic using Gulf ports, impacts 

on coastal environments from the proposed oil transport operation is considered to range from negligible 

to adverse but not significant, depending upon the nature of adjacent coastal environments. 

There are no new navigation channels planned; however, there is potential for maintenance dredging 

of existing channels to assure appropriate depths for the shuttle tankers. This dredged material will be 

beneficially used either for wetland creation or beach restoration. 

While offshore oil spills could pose problems for beaches and nearshore barrier islands, these coastal 

features would be the most susceptible to inshore spills associated with vessel collisions, offloading, or 

pipeline breaks. Due to the proximity of the proposed work to the nearest coastal barrier islands (85-90 

mi or 137-145 km), the oil is expected to be sufficiently weathered such that the toxicity of the oil 

reaching the barrier or mainland beaches would be little to none. The combined probability of a spill 

greater than or equal to 1,000 bbl occurring from the proposed activities and contacting shoreline 

resources within 30 days from the Phoenix Project launch area is <0.5 percent. Given the distance of the 

proposed action from shore and the shore base (91-105 mi or 146-169 km), spills are expected to weather 

and would generally not reach shore. Given this low probability of a spill ocurring as a result of the 

proposed action and contacting a coastal barrier beach, the risk of spills from the Phoenix production site 

to coastal barrier beaches in the Gulf of Mexico is low.

The likelihood of contact of spilled materials with coastal barrier beaches and associated dunes is 

dependent on the meteorological and current conditions at the time of the spill and on the quantity and 

location of the spill. In coastal Louisiana, the heights of dune lines range from 1.6 to 4 ft (0.5 to 1.3 m) 

above mean high tide levels. For spilled oil to move onto beaches or across dunes, strong southerly winds 

must persist for an extended time prior to or immediately after the spill approaches the shoreline to 

elevate water levels. Strong winds would accelerate oil-slick dispersal, spreading, and weathering, 

thereby reducing impact severity at a landfall site. Any coastal barrier beach or associated dune contacted 

by a spill associated with the proposed activity is very unlikely, except during abnormally high water 

levels, such as might occur during a hurricane. A study in Texas showed that oil disposal on sand and 

vegetated sand dunes had little deleterious effects on the existing vegetation or on the recolonization of 

the oiled sands by plants (Webb, 1988). Oil or its components that remain in the sand after cleanup may 

be (1) released periodically when storms and high tides resuspend or flush beach sediments, (2) 

decomposed by biological activity, or (3) volatilized and dispersed during hot or sunny days. 

The cleanup impacts of these spills could result in a short-term (up to 2 years) adjustment in beach 

profiles and configurations as a result of sand removal and disturbance during cleanup operations. Some 

contact to the lower areas of sand dunes is expected. These contacts would not result in significant 

destabilization of the dunes. The long-term stressors to coastal barrier beach communities caused by the 

physical effects and chemical toxicity of an oil spill may lead to decreased primary production, plant 

dieback, and hence further erosion. 

In summary on a local basis, oil spills from the Phoenix operations could produce either adverse (but 

not significant) or extended (but not irreversible) impacts on coastal barrier beaches, depending upon spill 

size, the nature of the oil coming ashore (e.g., highly vs. lightly weathered), and the location and 

characteristics of the coastal barrier beach. Impacts may be long term, depending upon spill location and 

the relative position of sensitive resources. However, the combined probability of a spill >1,000 bbl 

contacting coastal barrier beaches and associated dunes in any county or parish within 30 days is 

extremely low (≤.5%). Modeled locations indicate smaller spills are not predicted to reach these beaches 

or the associated wetlands. 

3.2.1.1.3 Cumulative Analysis 

Barrier beaches along coastal Louisiana and Texas have experienced severe erosion and landward 

retreat (marine transgression) because of natural processes enhanced by human activities. Mississippi, 

Alabama, and Florida have also experienced beach erosion and shoreline depletion in varying degrees as a 

result of recent hurricanes, i.e., Hurricanes Katrina, Rita, Ivan, and Wilma (USDOC, NMFS, 2007). The 

cumulative effect of these barrier island losses will continue as future tropical storms and hurricanes 

approach these coasts and further degrade these barriers. 

Impact-producing factors from non-OCS activity that contribute to coastal barrier beach and dune 

erosion, or conversion to another environment, include (1) levee construction and stabilization structures 

for channels and beaches; (2) natural processes such as hurricanes, erosion, and subsidence; (3) 
26 

recreational vehicle use on dunes and beaches; (4) recreational and commercial development; and (5) 

removal of coastal vegetation. Deterioration of Gulf barrier beaches is expected to continue in the future. 

The scenario of impact-producing factors related to OCS activity may include pipeline emplacement, 

and vessel-induced erosion. Accidental impact producing factors include oil spills and the resultant beach 

cleanup. However, due to the distance of the proposed OCS activity from shore, the absence of pipeline 

landfalls, and the minimal shuttle-tanker trips, only the following impact-producing factors could 

potentially affect the coastal barrier beaches and associated dunes. These impact-producing factors would 

include the minimal (<5% chance) potential of beach oiling from oil spills and the minimal potential for 

vessel-related erosion. Additional OCS activities in the foreseeable future could include the need for 

pipeline emplacement, onshore facilities, and increased supply vessel and tanker support for potential 

increases in the construction of floating production, storage, and offloading systems in the GOM. 

The incremental contribution of the proposed action’s impacts to the cumulative impact on coastal 

barrier beaches and associated dunes is negligible and likely undetectable among the other cumulative 

impacts. However, if future pipeline installations are necessary, avoidance procedures for pipeline 

emplacement near coastal barrier beaches and associated dunes have been included in “conditioned 

permits” required by the Corps of Engineers. These procedures assure that pipeline activities near these 

sensitive beaches are placed under the islands and beaches using indirect drilling techniques, or the 

pipeline routing is planned to avoid these sensitive areas. 

3.2.1.2. Wetlands 

3.2.1.2.1 Description 

A detailed description of the coastal wetlands can be found in Chapter 3.2.1.2 of the Multisale EIS 

and are hereby incorporated by reference into this PEA. The following information is a summary of the 

impact analysis incorporated from the Multisale EIS (USDOI, MMS, 2007). Wetland habitats found 

along the Central and Western Gulf Coast include fresh, intermediate, brackish, and saline marshes; mud 

and sand flats; and forested wetlands of mangrove swamps, cypress-tupelo swamps, and bottomland 

hardwoods. Coastal wetland habitats occur as bands around waterways and as broad expanses. Saline 

and brackish habitats support sharply delineated, segregated stands of single plant species. Fresh and 

very low salinity environments support more diverse and mixed communities of plants. The plant species 

that occur in greatest abundance vary greatly around the Gulf. These wetlands are high in organic 

activity, producing needed nutrients to adjacent waters and marshes that, in turn, provide habitat for a 

great number and wide diversity of invertebrates, fish, reptiles, birds, and mammals. These wetlands also 

provide nutrient recycling and detrital production so important in making these areas particularly 

important as nursery grounds for many fish and shellfish juveniles that, in turn, support a thriving fishing 

industry. Louisiana’s coastal wetlands support more than two-thirds of the wintering waterfowl 

population of the Mississippi Flyway, including 20-25 percent of North America’s puddle duck 

population. Louisiana’s coastal region also supports the largest fur harvest in North America (Olds, 

1984). 

During 1997, the area of interest in Louisiana contained about 708,570 ha (1,750,915 ac) of coastal 

wetlands. About 32,570 ha (80, 482 ac) of this were freshwater marsh and forests, 175,560 ha (433,818 

ac) were intermediate salinity marsh, and 207,440 ha (512,595 ac) were brackish marsh (Louisiana Dept. 

of Wildlife and Fisheries, 1997). Presumably, the remaining 293,000 ha (724,018 ac) were saline marsh. 

These wetlands largely occur as broad expanses. More recent information is provided below by 

geographic area, including recent land change as a result of Hurricanes Katrina and Rita. The most 

notable was the 217 mi2

 (562 km2) of Louisiana’s coastal lands that were transformed to water after 

Hurricanes Katrina and Rita (Barras, 2006). Based on the analysis of the latest satellite imagery (Barras, 

2007a and b) approximately 82 mi2

 (212 km2) of new water areas were in areas primarily impacted by 

Hurricane Katrina (Mississippi River Delta Basin, Breton Sound Basin, Pontchartrain Basin, and Pearl 

River Basin), whereas 117 mi2

 (256 km2) were in areas primarily impacted by Hurricane Rita 

(Calcasieu/Sabine Basin, Mermentau Basin, Teche/Vermillion Basin, Atchafalaya Basin, and Terrebonne 

Basin). Barataria Basin contained new water areas caused by both hurricanes, resulting in some 18 mi2

(46.6 km2

) of new water areas. 

These new water areas represent landlosses caused by the direct removal of wetlands. They also 

indicate transitory changes in water area caused by remnant flooding, removal of aquatic vegetation, 

scouring of marsh vegetation, and water-level variation attributed to normal tidal and meteorological 
27 

variation between satellite images. It was noted (Barras, 2006) that permanent losses cannot be estimated 

until several growing seasons have passed and the transitory impacts of the hurricanes are minimized. It 

is, however, too early to estimate the actual overall marsh loss. 

3.2.1.2.2. Impact Analysis 

The primary impact-producing activities associated with routine activities for the proposed action that 

could affect wetlands include maintenance of existing navigation channels, vessel traffic-related erosion, 

disposal of OCS-related wastes, and use of support infrastructure in these coastal areas. Other potential 

impacts that are indirectly associated with OCS oil and gas activities are wake erosion resulting from 

navigation traffic, levee construction that prevents necessary sedimentary processes, sediment 

management structures (i.e., groins, jetties, and breakwaters), saltwater intrusion that changes the 

hydrology leading to unfavorable conditions for wetland vegetation, and vulnerability to storm damage 

from eroded wetlands. There are no new onshore facilities proposed for the proposed action at this stage 

of planning. There are currently disposal sites designated for OCS-related waste products as well as oil 

and gas support facilities located in the coastal wetlands that are capable of supporting existing activity in 

addition to that projected for the current exploration and production area. Due to the expected zero new 

pipeline landfalls from the proposed action and proposed use of existing processing facilities, no further 

expansion of either of the types of facilities should involve wetland expansions. 

The addition of the proposed routine activities associated with the inclusion of the current project 

would have minimal to no direct effect on the coastal wetlands because the activities are 91 and 105 mi 

(146 and 169 km) from the nearest shoreline and shore base, respectively. The potential for indirect 

impacts may exist due to the initial needs for shore-based supply vessel support. Only a slight increase in 

vessel traffic is expected to occur but vessel size may increase due to supply needs and open-sea 

conditions. Transport vessels involved with the project consist of crewboats and work boats, each making 

no more than two trips per week. Helicopter trips are also expected to minimally increase with 

approximately three trips/week. Neither of the increases in support activity would require an expansion 

of onshore base support and, therefore, would not directly impact coastal wetlands. Port Fourchon is 

projected to be the primary base of onshore support operations and can be accessed by an armored 

channel. Since the vessel support will be using primarily armored coastal channels as well as existing 

offshore channels and sea lanes, vessel-related erosion should be minimal and the need for channel 

maintenance should not significantly increase as a result of the proposed activity. 

The primary accidental impact-producing factors with the potential to affect the coastal wetlands are 

generally oil spills and, most specifically the coastal and inland spills resulting from vessel collisions or 

pipeline breaks adjacent to the coastal wetlands. While there is potential for accidental offshore spills 

affecting the coastal wetlands, the proximity of the lease site (91-105 mi; 146-169 km) to the nearest coast 

plus the probable weathered condition of the oil that may reach the shoreline minimizes the impact of 

these types of spills. Barrier islands can provide protection or reduce the severity of an oil spill by 

intercepting the spill before it reaches the wetlands located either behind (on mainland shore) or within 

the interior of the islands. Due to the lower post-hurricane (Hurricanes Katrina and Rita) elevations of the 

barrier islands along the Louisiana coast and to some extent the Texas coas,t there is now a greater chance 

of spilled oil reaching mainland shores (USDOC, NOAA/NMFS, 2007). 

Trajectories of an offshore oil spill and the probability of it impacting a land segment have been 

projected using the MMS Oil-Spill Risk Analysis Model as described in Appendix B. The combined risk 

of a spill occurring and contacting Louisiana or Texas coastal counties and parishes within 3-30 days was 

<0.5%. There are concerns that offshore spills may contribute to wetland damage; however, due to the 

distance of the proposed action offshore, the possibility of spills reaching coastal wetlands with the 

toxicity to significantly impact the coastal wetlands is low. The toxicity of the spilled oils is greatly 

reduced or eliminated by weathering and wave action. The works of several investigators (Webb et al., 

1981 and 1985; Alexander and Webb, 1983 and 1987; Lytle, 1975; Delaune et al., 1979; Fischel et al., 

1989) evaluated the effects of potential spills to area wetlands. For wetlands along the central Louisiana 

coast, the critical oil concentration is assumed to be 1.0 L/m2

 of marsh. Concentrations above this would 

result in longer term effects to wetland vegetation, including some plant mortality and landloss. 

Concentrations less than this may cause diebacks for one growing season or less, depending upon the 

concentration and the season during which contact occurs. Chapter 4.3 of the Multisale EIS has a 

complete discussion of oil spills, the various impacting factors, and risk analysis; Chapter 4.4.3.2 of the 

Multisale EIS specifically addresses the types and severity of wetland impacts. 
28 

The fate and behavior of oil spills, availability and adequacy of oil-spill containment and cleanup 

technologies, oil-spill cleanup strategies, impacts of various oil-spill cleanup methods, effects of 

weathering on oil spills, toxicological effects of fresh and weathered oil, air pollution associated with 

spilled oil, and short-term and long-term impacts of oil on wetlands are additional accidental concerns. 

Offshore oil spills resulting from the proposed action are not expected to damage significantly any 

wetlands along the Gulf Coast. However, if an inland oil spill related to the proposed action occurs, some 

impact to wetland habitat would be expected. Although the probability of occurrence is low, the greatest 

threat to wetland habitat is from an inland spill resulting from a vessel accident or pipeline rupture. While 

a resulting slick may cause minor impacts to wetland habitat, the equipment and personnel used to clean 

up a slick over the impacted area may generate the greatest impacts to the area. Associated foot traffic 

may work oil farther into the sediment than would otherwise occur. Close monitoring and restrictions on 

the use of bottom-disturbing equipment would be needed to avoid or minimize those impacts. 

Conclusion 

There is a very low probability of a spill from the well sites occurring and contacting wetland 

environments due to the proximity to shore, absence of nearshore pipeline emplacement, and minimal 

vessel transport of product. Based on the low frequency of port visits the probability of impacts to coastal 

wetlands would be small. Should a spill make landfall and a cleanup proceed with approved procedures, 

impacts to wetlands would be minimal due to the weathered condition of the oil and the containment and 

cleanup techniques. Recovery periods longer than 2 years would be very unlikely. Therefore, no 

significant, long-term impacts to the structure or vitality of wetlands would be expected to occur from 

accidental spills of oil and diesel fuel. 

During routine operations, vessel traffic will produce an incremental, if any, increase in erosion rates, 

sediment resuspension, and turbidity, an adverse but not significant impact to coastal wetland since the 

ports used can be approached using armored approach channels.

3.2.1.2.3. Cumulative Analysis 

This cumulative analysis considers the effects of impact-producing factors related to the proposed 

action, prior and future OCS sales, State oil and gas activities, other governmental and private projects 

and activities, and pertinent natural processes and events that may occur and adversely affect wetlands. 

Conversion of wetlands to agricultural, residential, recreational, and commercial uses has generally been 

the major cause of wetland loss. The loss of wetlands is projected to continue in the Gulf Coast States. 

Deltaic Louisiana will continue to experience the greatest losses; wetland loss is also expected to continue 

in coastal Texas, Mississippi, Alabama, and Florida, but at slower rates. Approximately 2.1-2.4 percent 

of coastal wetland losses can be attributed to OCS oil and gas activities. The proposed action would 

represent a fraction of a percent contribution to these impacts. 

Cumulative impacts on wetlands include the sources identified in Chapter 4.4.3 of the Multisale EIS 

(USDOI, MMS, 2007) and are hereby incorporated by reference into this PEA. Because 90 percent of 

coastal Louisiana is <1 m (3.3 ft) above sea level, subsidence and transgression of the sea can cause 

significant wetland loss or conversion into different environments. Estimates for wetland loss or 

conversion vary but most reported rates are close to 25 mi2

 (65 km2) per year. A recent estimate predicted 

that about 640,000 ac (258,999 ha) of existing wetlands will be submerged in less than 50 years 

(Louisiana Coastal Wetlands Conservation and Restoration Task Force, 1993). There is increasing new 

evidence of the importance of the effect of sea-level rise (or marsh subsidence) as it relates to the loss of 

marsh or changes in marsh types and plant diversity (Spalding and Hester, 2007). This study shows that 

the very structure of coastal wetlands will likely be altered by sea-level rise, as community shifts will be 

governed by the responses of individual species to new environmental conditions. The effects of 

pipelines, canal dredging, navigation activities, and oil spills on wetlands are described in Chapters 

4.2.1.1.3.2, 4.2.2.1.3.2, and 4.4.3.2 of the Multisale EIS. Subsidence of wetlands is discussed in more 

detail in Chapter 4.1.3.3.1 of the Multisale EIS (USDOI, MMS, 2007). 

The continued increasing U.S. demand for petroleum combined with decreased domestic production 

will increase the need for imports, thereby increasing the tanker traffic and the need for more onshore 

production facilities. Consequently, it is the increases in oil imports in the form of increased tanker 

transits into GOM refinery ports and terminals that will drive the cumulative increase for the risk of oil 

spills. Impacts from State onshore oil and gas activities are expected to occur as a result of dredging for 
29 

new canals, maintenance and usage of existing rig access canals and drill slips, and preparation of new 

well sites. Both of these activities (increased tanker traffic and State onshore oil and gas activities) may 

impact wetlands either through vessel-generated erosion or by requiring the expansion of production 

facilities into the wetlands. 

Insignificant adverse impacts upon wetlands from maintenance dredging are expected because the 

large majority of the material would be disposed upon existing disposal areas. Alternative, dredged 

material disposal methods can be used to enhance and create coastal wetlands. Depending upon the 

regions and soils through which they were dredged, secondary adverse impacts of canals may be more 

locally significant than direct impacts. Additional wetland losses generated by the secondary impacts of 

saltwater intrusion, flank subsidence, freshwater-reservoir reduction, and deeper tidal penetration have not 

been calculated because of a lack of quantitative documentation; MMS has initiated a project to document 

and develop data concerning such losses. 

Wetlands will continue to be impacted by natural events such as hurricanes, subsidence, saltwater 

intrusion, and sea-level rise. There is increasing new evidence of the importance of the effect of sea-level 

rise (or marsh subsidence) as it relates to the loss of marsh or changes in marsh types and plant diversity 

(Spalding and Hester, 2007). This study shows that the very structure of coastal wetlands will likely be 

altered by sea-level rise, as community shifts will be governed by the responses of individual species to 

new environmental conditions. In addition, the State of Louisiana has made provisions for wetlands 

protection and restoration part of the State’s plan for hurricane protection. As climatic patterns vary, 

drought conditions may induce a need for additional reservoir storage and, as a result, alter the freshwater 

input into the coastal wetlands. Based of the reduction in freshwater input, salinity modifications may 

alter wetland type and, in some cases, allow for increased salinity intrusion into fresh marshes. The 

Louisiana State legislature established the Coastal Protection and Restoration Authority and charged it 

with coordinating the efforts of local, State, and Federal agencies to achieve long-term and 

comprehensive coastal protection and restoration that integrates flood control and wetland restoration. 

In summary, the effects to coastal wetlands from the primary impact-producing activities associated 

with the proposed action are expected to be low. Maintenance dredging of navigation channels and 

canals is expected to occur with minimal impacts; the proposed action is expected to contribute minimally 

to the need for this dredging. Alternative dredged material disposal methods can be used to enhance and 

create coastal wetlands. Vessel traffic associated with the proposed action is expected to contribute 

minimally to the erosion and widening of navigation channels and canals. Overall, impacts from these 

sources are expected to be low and could be further reduced through mitigation, such as horizontal 

directional (trench less) drilling techniques to avoid damages to these sensitive habitats. Secondary 

impacts to wetlands would be primarily from vessel traffic corridors and will continue, but the impact can 

range from minimal to moderate but not significant depending on whether offshore or inland ports are 

used. In addition, inland ports with armored access will be minimally affected by the vessel traffic. 

3.2.1.3. Alabama, Choctawhatchee, St. Andrew, and Perdido Key Beach Mice 

3.2.1.3.1. Description 

Sixteen subspecies of field mouse (Peromyscus polionotus) are recognized along the Gulf Coast, 

eight of which are collectively known as beach mice. The Alabama, Choctawhatchee, St. Andrew, and 

Perdido Key beach mice are designated as protected species under the Endangered Species Act (ESA) 

because of the loss of coastal habitat (USDOI, MMS, 2007). 

Beach mice are characterized in Chapter 3.2.5 of the Multisale EIS (USDOI, MMS, 2007) and are 

hereby incorporated by reference into this PEA. A summary of the incorporated material follows. 

Beach mice are restricted to the coastal barrier sand dunes along the Gulf Coast. Optimal overall 

beach mouse habitat is currently thought to be comprised of a heterogeneous mix of interconnected 

habitats including primary dunes, secondary dunes, scrub dunes, and interdunal areas. Beach mice dig 

burrows mainly in the primary, secondary, and interior scrub dunes where the vegetation provides suitable 

cover. Most beach mouse surveys conducted prior to the mid-1990’s were in primary and secondary 

dunes because the investigators assumed that these habitats are the preferred habitat of beach mice. 

Beach mice feed nocturnally in the dunes and remain in burrows during the day. Their diets vary 

seasonally but consist mainly of seeds, fruits, and insects (Ehrhart, 1978; Moyers, 1996). Changes in the 
30 

availability of foods result in changes in diets between seasons and account for variability of seasonal 

diets between years. 

Hurricanes are a natural environmental phenomenon affecting the Gulf Coast, and beach mice have 

evolved and persisted in coastal dune habitats since the Pleistocene. Hurricanes are part of a repeated 

cycle of destruction, alteration, and recovery of dune habitat. The extensive coastal dune habitat that 

existed along the Gulf Coast before the fairly recent commercial and residential development allowed 

beach mice to survive even the most severe hurricane events to repopulate dune habitat as it recovered. 

Beach mice are affected by the passage of hurricanes along the northwest Florida and Alabama Gulf 

Coast. Since records on hurricane intensity began in 1885, a total of 32 hurricanes have struck northwest 

Florida within the historic ranges of the four Gulf Coast beach mouse subspecies (Williams and Duedall, 

1997; Doering et al., 1994; Neumann et al., 1993). In addition, 22 hurricanes have made landfall along 

the coast of Alabama from 1851 to 2004 (USDOC, NOAA, National Hurricane Center, 2006). 

Beach mice have existed in an environment subject to recurring hurricanes, but tropical storms and 

hurricanes are now considered to be a primary factor in the beach mouse’s decline. It is only within the 

last 20-30 years that the combination of habitat loss due to beachfront development, isolation of 

remaining beach mouse habitat blocks and populations, and destruction of remaining habitat by 

hurricanes have increased the threat of extinction of several subspecies of beach mice. 

3.2.1.3.2. Impact Analysis 

The major impact-producing factors associated with the proposed action that may affect beach mice 

include (1) oil spills, (2) spill-response activities, and (3) beach trash and debris from OCS activity. 

Chapters 4.2.2.1.7 and 4.4.7 of the Multisale EIS (USDOI, MMS, 2007) contain a discussion of impacts 

from OCS activity and are hereby incorporated by reference into this PEA. The incorporated materials 

are summarized below. 

Direct contact with spilled oil that has washed ashore can cause skin and eye irritation, asphyxiation 

from the inhalation of fumes, oil ingestion, and reduction or contamination of food sources. Regardless 

of the potential for persistence of oil in beach mouse habitat, a slick cannot wash over the fore dunes 

unless carried by a heavy storm swell. High seas would be necessary to cause a spill slick to landfall and 

affect mice or their habitat. The erosion associated with high seas during storms is likely to do more 

damage to beach mouse habitat than oiling. 

Vehicular traffic and activity associated with oil-spill cleanup can trample or bury nests and burrows 

or cause displacement from preferred habitat. Trash and debris may be mistakenly consumed by beach 

mice or it may ensnare them; however, contact between mice and trash originating from the proposed 

development activities in Green Canyon is very unlikely. The impacts on beach mice from oil spills and 

cleanup activities are discussed in Chapter 4.4.7 of the Multisale EIS (USDOI, MMS, 2007) and are 

hereby incorporated by reference into this PEA. Oil spills or cleanup activity and incidental trash related 

to the proposed activity are not expected to significantly impact beach mice. 

Conclusion 

Impacts from the proposed development activities in the Green Canyon area on the Alabama, 

Choctawhatchee, St. Andrew, and Perdido Key beach mice are unlikely. Impacts may result from the 

consumption of beach trash and debris. The proposed activities would deposit only a small portion of the 

total debris that would reach the habitat. Efforts undertaken for the removal of marine debris may 

temporarily scare away beach mice, destroy their food resources, or collapse the tops of their burrows. 

Given the low probability of a large (≥1,000 bbl) oil spill occurring, direct impacts of spills on beach 

mice from the proposed action are highly unlikely. Oil-spill response and cleanup activities could have 

significant impact on the beach mice and their habitat if not properly regulated. 

3.2.1.3.3. Cumulative Analysis 

Cumulative activities have a potential to harm or reduce the numbers of Alabama, Choctawhatchee, 

St. Andrew, and Perdido Key beach mice. Those activities include oil spills, alteration and reduction of 

habitat, predation and competition, and consumption of beach trash and debris. Spills from the Phoenix 

development activities, as well as oil spills stemming from service vessels, are not expected to contact 

beach mice or their habitats. Cumulative activities posing the greatest potential harm to beach mice are 
31 

non-OCS activities (beach development and coastal spills) and natural catastrophes (hurricanes), which, 

in combination, could potentially deplete some beach mice populations to unsustainable levels. The 

expected incremental contribution of the proposed development activities to the cumulative impacts is 

negligible. 

3.2.2. Sensitive Offshore Resources 

Sensitive offshore environments in the Central Gulf are characterized in Chapters 3.2.2, 3.2.3, 3.2.4, 

3.2.6, 3.2.7, and 3.2.8 of the Multisale EIS (USDOI, MMS, 2007) and are hereby incorporated by 

reference into this PEA. Summaries of these resources follow and include (1) deepwater benthic 

communities, (2) marine mammals, (3) sea turtles, (4) essential fish habitat and fish resources, (5) Gulf 

sturgeon, and (6) coastal and marine birds. 

The impact-producing factors associated with the proposed Phoenix Project in Green Canyon Blocks 

236 and 237 that could affect deepwater benthic communities, marine mammals, sea turtles, essential fish 

habitat and fish resources, Gulf sturgeon, and coastal and marine birds include (1) physical contact with 

anchors, mooring lines, and other engineered structures; (2) noise in the air and sea; (3) collisions with 

vessels; (4) lights in the remote offshore environment; (4) spilled oil and response activities; (5) effluent 

discharges; and (6) solid trash and debris. Discussions of the impacts from OCS activity on deepwater 

benthic communities, marine mammals, sea turtles, essential fish habitat and fish resources, Gulf 

sturgeon, and coastal and marine birds can be found in Chapters 4.2.1.1.4 through 4.2.1.1.8, 4.2.2.1.4 

through 4.2.2.1.6, 4.2.2.1.8 through 4.2.2.1.10, and 4.4.10 of the Multisale EIS (USDOI, MMS, 2007) and 

are hereby incorporated by reference into this PEA. 

Of these potential impact-producing factors, oil spills represent a high consequence and lowprobability accidental event. No blowouts are projected as a result of development drilling, well 

completions, workovers, or hydrocarbon production associated with the Phoenix Project based on 

historical trends in the GOM (Table B-1). Spills that occur from development and production activity for 

the Phoenix Project would be few (if any), volumetrically small, and be located near project activities in 

Green Canyon Blocks 236 and 237. 

Table B-4 indicates Gulfwide oil-spill occurrence rates. The statistics show that there have been 

numerous spills of >1 but <50 bbl but very few spills ≥1,000 bbl for all OCS operations per billion barrels 

of oil handled. A blowout is the only accident category that could yield a spill ≥1,000 bbl over the 5-year 

life cycle of Phoenix field production. The probability of a blowout is small, less than 1 in 100,000, and 

the combined probability of a spill ≥1,000 bbl making landfall in Louisiana or adjacent states would be 

extremely small (<0.5%). 

Spills occurring in the deepwater environment of Grid 9 would not be large enough to enable them to 

persist long enough in the marine environment before weathering processes significantly degrade the spill 

before it makes landfalls. The transport time would allow a slick to weather, dissolve, and disperse while 

still in the marine environment. If a spill occurs at sea, mechanical cleanup is assumed to collect up to 10 

percent of spilled oil and approximately 30 percent is assumed to be chemically dispersed, further 

reducing the overall probability and severity of spills that may move inshore. Because the landfall of 

spilled oil, diesel fuel, drilling fluids, or chemicals is highly unlikely, the potential impacts from spill 

landfall, i.e., response and cleanup activities on coastal barrier beaches and associated dunes and 

wetlands, are not expected to be incurred. 

Cumulative impacts on sensitive offshore resources include those that affect animals living in and on 

the sea bottom and in the water column, as well as those animals that require nearshore or coastal 

resources for part of their lifecycle. The cumulative impacts on these resources are discussed below. 

3.2.2.1. Deepwater Benthic Communities 

3.2.2.1.1. Nonchemosynthetic Communities 

3.2.2.1.1.1. Description 

The description of the biology, life history, and distribution of nonchemosynthetic deepwater benthic 

communities can be found in Chapter 3.2.2.2.2 of the Multisale EIS. The vast majority of the GOM has a 

soft, muddy bottom in which burrowing infauna are the most abundant invertebrates. The Green Canyon 

Blocks 236 and 237 area falls into this category, and proposed wells are at a water depth ranging from 
32 

1,630 to 2,335 m (5,346 to 7,724 ft). Using complete 3D seismic seabed amplitude anomaly coverage of 

the area, no new hard bottoms were discovered in Green Canyon Block 236. There are no known hardbottom areas in Green Canyon Block 236, and an area of Green Canyon Block 237 with some potentially 

exposed hard bottom is well removed from impacting activities (see also Chapter 3.2.2.1.2, 

Chemosynthetic Communities). 

As in all areas of the Gulf, a wide variety of organisms, ranging from single-celled bacteria to 

invertebrates and fish, inhabit soft-bottom habitat at almost every depth range in the Gulf of Mexico. 

These organisms can also include chemosynthetic animals, a remarkable assemblage of invertebrates 

found in association with hydrocarbon seeps that use a carbon source independent of photosynthesis and 

the sun-dependent photosynthetic food chain that supports most all other life on earth. This unique group 

is discussed in Chapter 3.2.2.1.2. Also, recent study results in Rowe and Kennicutt (2002) have 

indicated some unique areas of soft-bottom communities with substantially higher community biomass 

and carbon flux near the Mississippi River Delta. 

The continental slope in the GOM extends from the edge of the continental shelf at about 200 m 

(656 ft) to a water depth of approximately 3,000 m (9,840 ft). Green Canyon Blocks 236 and 237 lie in 

the mid levels of the continental slope, which corresponds to the depth zone termed archibenthal, as 

characterized by Pequegnat (1983) and Gallaway et al. (1988). 

The vast majority of the GOM seabed is comprised of soft sediments. Major groups of animals that 

live in this habitat include (1) bacteria and other microbenthos, (2) meiofauna (0.063-0.3 mm (0.00248-

0.0118 in)), (3) macrofauna (>0.3 mm (0.0118)), and (4) megafauna (larger organisms such as crabs, sea 

pens, sea cucumbers, crinoids, and bottom-dwelling (demersal) fish). All of these groups are represented 

throughout the entire Gulf—from the continental shelf to the deepest abyssal depths (about 3,850 m or 

12,630 ft). Basic descriptions of typical soft-bottom fauna (bacteria, meiofauna, macrofauna, and 

megafauna) are addressed in Chapter 3.2.2.2 of the Multisale EIS. Representatives from all of these 

groups would be expected in the Phoenix Green Canyon Blocks 236 and 237 area. A great number of 

publications have been derived from two major MMS-funded deep Gulf studies; Rowe and Kennicutt 

(2002) and Gallaway et al. (1988). These two studies provide for extensive background information on 

deepwater GOM habitat and biological communities. 

3.2.2.1.1.2. Impact Analysis 

The potential impacts to nonchemosynthetic deepwater benthic communities expected to inhabit 

Green Canyon Blocks 236 and 237 are discussed below. 

The impact-producing factors associated with exploration of the Phoenix Project in Green Canyon 

Blocks 236 and 237 that could affect nonchemosynthetic deepwater benthic communities include (1) 

drilling discharges, including primarily cuttings with adhering drilling muds, and (2) seafloor disturbance 

from possible blowouts during well drilling. The deepwater ecosystem in Green Canyon Blocks 236 and 

237 can be characterized as vast expanses of soft-bottom faunas. The topography is sloped to the south, 

decreasing in depth around 700 m (2,297 ft) between the shallowest and deepest well sites. 

The most important impact-producing factors on nonchemosynthetic deepwater benthic communities 

are physical disturbances of the seafloor caused by the deposition of drilling cuttings and associated 

drilling fluids. Significant accumulation thickness will be limited to a relatively close distance from the 

surface discharge point. A recent study looked at both exploratory and production facility drilling 

discharges in water depths of 1,000 m (3,280 ft) and reported detectable accumulations at distances as far 

as 1 km (0.6 mi) (CSA, 2006). Geophysically mapped thicknesses of cuttings accumulations at one site 

showed a rapid decrease of thickness with increasing distance from the well site. Accumulation thickness 

was less than 7.6 cm (3 in) within 240 m (787 ft) of the well site. The maximum bottom area disturbed in 

any way is estimated to be no larger than 315 ha (778 ac), assuming the worst case of muds and cuttings 

discharges reaching distances of 1,000 m (3,280 ft) from the well site in every direction (CSA, 2006). 

Realistically, splays of discharges only move to limited directions depending on prevailing currents; a 

good estimate would be 1/3 of the radius of a circle or 105 ha out to 1,000 m (260 ac out to 3,280 ft). 

This would not result in a significant impact on the nonchemosynthetic benthic communities because the 

duration and areal extent of the proposed activities would be limited, and recolonization of benthic 

communities is facilitated from nearby surrounding areas. 

A DP semisubmersible platform will be used to drill new wells; therefore, there will be no new 

impact from anchoring. The DP semisubmersible drilling rig will be installed near the previous position 

of the Typhoon TLP that was destroyed by Hurricane Rita in September 2005. Anchor impacts from the 
33 

buoy installation (for use with the FPU) will extend farther from this location but remain in areas of soft 

mud-bottom habitat. 

A blowout at the seafloor could create a crater on the sea bottom and resuspend and disperse large 

quantities of bottom sediments within a 300-m (984-ft) radius of the blowout site, burying both infaunal 

(live in the sediment) and epifaunal (live on sediment) organisms and interfering with sessile invertebrates 

that rely on filter-feeding organs. Impacts of rapid burial are discussed in Chapter 4.1.1 in the Multisale 

EIS. Similar to impacts from drill cuttings, impacts from a blowout would be limited because the 

duration and areal extent would be limited, and recolonization of communities is facilitated from nearby 

surrounding areas. 

Conclusion 

The proposed Phoenix Project is expected to have negligible impacts on the ecological function, 

biological productivity, or distribution of soft-bottom, nonchemosynthetic benthic communities. Bottom 

disturbances from the discharge of drilling cuttings and associated drilling muds will not be of a sufficient 

size or duration to adversely affect these benthic community types to any significant or permanent degree. 

Minor and temporary impacts, such as interference with filter-feeding structures, could occur over areas 

inside an envelope estimated to be no more than about 105 ha out to 1,000 m (260 ac out to 3,280 ft). 

Routine discharges are not expected to adversely impact these community types because of the water 

depths in Green Canyon Blocks 236 and 237. Anchor impacts from the installation of a buoy will be 

minor and similar to the previously installed Typhoon TLP near the same site. Bottom disturbance from a 

blowout during the drilling of the wells is not likely based on the historical record of blowout events in 

the Gulf. Recruitment of new organisms would take place from nearby areas, and organisms from 

undisturbed areas are free to migrate into disrupted areas after the disturbance ceases. 

3.2.2.1.1.3. Cumulative Analysis 

Cumulative impacts on nonchemosynthetic deepwater benthic communities include crushing and 

physical disturbance of the sea bottom from drilling discharges and emplacement of other drilling rigs, 

production platforms, and subsea production infrastructure. The water depth in the Green Canyon Blocks 

236 and 237 area ranges from 1,630 to 2,335 m (5,346 to 7,724 ft). These depths are too deep for 

anchoring by service vessels, which will use a mooring buoy system. There are no non-OCS activities 

(e.g., commercial bottom trawling) that could cause sea-bottom disturbances. The cumulative impacts on 

nonchemosynthetic benthic communities are expected to cause little damage to the ecological function or 

biological productivity of the expected typical communities existing on sand/silt/clay bottoms of the deep 

Green Canyon Blocks 236 and 237 area of the GOM. Large motile animals would tend to move, and 

recolonization from populations from neighboring substrates would be expected in any areas impacted by 

any form of burial. 

3.2.2.1.2. Chemosynthetic Communities 

3.2.2.1.2.1. Description 

The description of the chemosynthetic deepwater benthic communities in the GOM can be found in 

Chapter 3.2.2.2.1 of the Multisale EIS (USDOI, MMS, 2007). The following information is a summary 

of the description hereby incorporated by reference from the Multisale EIS. 

Chemosynthetic communities are defined as persistent, largely sessile assemblages of marine 

organisms dependent upon symbiotic chemosynthetic bacteria as their primary food source (MacDonald, 

1992). Chemosynthetic clams, mussels, and tube worms are similar to (but not identical with) the 

hydrothermal vent communities of the eastern Pacific (Corliss et al., 1979). Bacteria live within 

specialized cells in these invertebrate organisms and are supplied with oxygen and chemosynthetic 

compounds by the host via specialized blood chemistry (Fisher, 1990). The host, in turn, lives off the 

organic products subsequently released by the chemosynthetic bacteria and may even feed on the bacteria 

themselves. Additional information on the biology, life history and distribution of chemosynthetic 

deepwater benthic communities can be found in Chapter 3.2.2.2 of the Multisale EIS (USDOI, MMS, 

2007). 
34 

Chemosynthetic communities in the CPA have been reported to occur at water depths between 290 

and 2,743 m (951 and 9,000 ft) (USDOI, MMS, 2007). The total number of chemosynthetic communities 

in the Gulf is now known to exceed 60. A recent MMS study, Investigations of Chemosynthetic 

Communities on the Lower Continental Slope of the Gulf of Mexico (Brooks et al., in press), has 

performed exploration surveys specifically targeting water depths below 1,000 m (3,280 ft). This project 

confirmed the presence of 12 additional chemosynthetic communities not previously know in these water 

depths. What was initially thought to be relatively rare occurrences of chemosynthetic communities is 

now known to be far more common and regularly associated with primary geophysical signatures of the 

seabed including faulting with conduits for hydrocarbons to the surface from deeper depths and 

precipitation of carbonate deposits on the sea floor. Anomalies of seismic survey acoustic amplitudes on 

the seabed is one major feature related to most all known chemosynthetic communities and these kinds of 

features are now relatively well mapped throughout the entire northern Gulf of Mexico. The total number 

of features on the northern Gulf slope that have probable associated communities now number in the 

thousands. 

A review for the potential occurrence of chemosynthetic communities associated with Green Canyon 

Blocks 236 and 237 for the proposed Phoenix Project was performed for this PEA. Green Canyon Blocks 

236 and 237 lie in a region with numerous areas of gas expulsion and areas of high probability for the 

presence of chemosynthetic communities. There is one major feature in Green Canyon Block 237 to the 

northwest of one well and the FPU location that is a high-probability area for chemosynthetic 

communities. Other high-probability areas occur to the northwest in Green Canyon Block 235, to the 

northeast in Green Canyon Block 193, to the southwest in Green Canyon Block 324, and to the southeast 

in Green Canyon Block 283. All but the feature in Green Canyon Block 237 lie several miles distant 

from the Phoenix activities. 

3.2.2.1.2.2. Impact Analysis 

A detailed impact analysis of the routine, accidental, and cumulative impacts of the proposed 

exploration activities on chemosynthetic communities can be found in Chapters 4.2.1.1.4.2.1, 

4.2.2.1.4.2.1, 4.4.4.2.1, and 4.5.4.1 of the Multisale EIS (USDOI, MMS, 2007). The following 

information is a summary of the impact analysis incorporated by reference from the Multisale EIS. 

The NTL 2000-G20, “Deepwater Chemosynthetic Communities,” makes mandatory the search for 

and avoidance of dense chemosynthetic communities (such as Bush Hill-type communities) or areas that 

have a high potential for supporting these community types, as interpreted from geophysical records. The 

NTL is exercised on all applicable leases and is not an optional protective measure. The closest feature 

with the potential to support chemosynthetic communities will be avoided by at least 1,550 ft (472 m) by 

both anchors and drilling discharges. There are no anticipated impacts to any chemosynthetic 

communities as a result of the Phoenix Project. 

Conclusion 

The proposed Phoenix Project is not expected to impact either known or probable areas of highdensity chemosynthetic communities. The nearest potential for any chemosynthetic community in 

proximity to Green Canyon Blocks 236 and 237 is approximately 1,500 ft (472 m) to the east of anchor 

leg #1 for the FPU in Green Canyon Block 237. No high-density chemosynthetic community 

components occur in the vicinity of the proposed drilling at any of the proposed six well sites in Green 

Canyon Blocks 236 and 237. 

3.2.2.1.2.3. Cumulative Analysis 

Cumulative impacts on chemosynthetic communities include the sources identified in Chapter 3.2.2.2 

of the Multisale EIS (USDOI, MMS, 2007). No additional impacts to chemosynthetic communities from 

either OCS or non-OCS-related activities would be expected. Normal fishing practices should not disturb 

the bottom in these areas. Bottom-disturbing activities such as trawling and boat anchoring are virtually 

nonexistent at water depths >400 m (1,312 ft). In addition, there are no chemosynthetic communities 

expected in any of the impacted areas. Cumulative impacts from activity in Green Canyon Blocks 236 

and 237 are not expected. No impacts from non-OCS-related activities would be expected. 
35 

3.2.2.2. Marine Mammals 

3.2.2.2.1. Description 

Twenty-eight cetaceans (whales and dolphins) and one sirenian (manatee) species have confirmed 

occurrences in the northern GOM (Davis and Fargion, 1996). Detailed information on each listed marine 

mammal species can be found in Chapter 3.2.3 of the Multisale EIS (USDOI, MMS, 2007) and is hereby 

incorporated by reference into this PEA, a brief summary follows. Cetaceans are divided into two major 

suborders: Mysticeti (baleen whales) and Odontoceti (toothed whales and dolphins). Of the six baleen 

whale species occurring in the Gulf, four are listed as endangered or threatened (Table 3-4 of the 

Multisale EIS (USDOI, MMS, 2007)). Of the 21 toothed whale species occurring in the Gulf, only the 

sperm whale is listed as endangered. The only member of the Order Sirenia found in the Gulf is the 

endangered West Indian manatee. The manatee has been reported in Louisiana coastal waters, but the 

coastal waters of Peninsular Florida and the Florida Panhandle are the manatee’s normal habitat. 

The MMS has been conducting scientific research of marine mammals in the GOM since 1991, 

including GulfCet I and II and the Sperm Whale Acoustic Monitoring Program (SWAMP). The most 

recent study, Sperm Whale Seismic Study (SWSS), completed four years of field work in 2005. This 

multi-faceted program involved numerous partners and researchers. Yearly reports have been published, 

and a synthesis report of the SWSS study will be published in 2008 (Jochens et al., 2008). These studies 

have shown that the GOM has a diverse and abundant marine mammal community, including a 

genetically-distinct resident population of the endangered sperm whale. 

3.2.2.2.2. Impact Analysis 

The impact-producing factors associated with exploration of the Phoenix Project that could affect 

marine mammals include (1) noise from vessel traffic, air traffic, and exploration activities; (2) 

degradation of water quality from oil spills or other material spills; (3) collision potential with service 

vessels; (4) spill-response activities; and (5) trash and debris from structures and service vessels. These 

impact-producing factors are the same for nonthreatened and nonendangered marine mammal species as 

well as those listed under the ESA. Chapters 4.2.1.1.5 and 4.2.2.1.5 of the Multisale EIS (USDOI, MMS, 

2007) contain a discussion of impacts from OCS activity and are hereby incorporated by reference into 

this PEA. 

Operations 

The noise and shadow from helicopter overflights, take-offs, and landings can cause a startle response 

and can interrupt whales and dolphins while resting, feeding, breeding, or migrating (Richardson et al., 

1995). Frequent overflights could have long-term consequences if they repeatedly or consistently disrupt 

important life functions such as feeding and breeding. 

The proposed action is expected to have three helicopter roundtrips per week, as needed. These 

occurrences would be temporary and pass within seconds. As more industry development projects occur 

in the area, helicopter activity is expected to increase. However, marine mammals are not expected to be 

adversely affected by routine helicopter traffic operating at prescribed altitudes. 

Many types of plastic materials end up as solid waste during drilling and production operations. 

Some of this material is accidentally lost overboard where whales and dolphins can consume or become 

ensnared in it. The result of plastic ingestion is certainly deleterious and could be lethal. The probability 

of a marine mammal encountering trash that appears edible is probably very low. The disposal of solid 

wastes offshore takes place in covered bins that are warehoused in a secure area on the DP 

semisubmersible, and the bins are returned to shore by service vessels for disposal. 

Service vessels present a collision hazard to marine mammals. The Phoenix Project is expected to 

require two supply-vessel and crew-vessel roundtrips per week. The consequence of a vessel collision 

and a marine mammal is likely to be lethal, but the probability of a collision taking place is low with the 

current mitigations in place. 

Accidental Events 

Spills that occur from Phoenix Project would be few (if any) if they did occur. Oil spills and spillresponse activities have the potential to adversely affect whales and dolphins by causing soft tissue 
36 

irritation, fouling of baleen plates, respiratory stress from inhalation of toxic fumes, food reduction or 

contamination, direct ingestion of oil and/or tar, and temporary displacement from preferred habitats or 

migration routes. Some short-term (months) effects of oil may be as follows: (1) changes in cetacean 

distribution associated with avoidance of aromatic hydrocarbons and surface oil; (2) changes in prey 

distribution and human disturbance; (3) increased mortality rates from ingestion or inhalation of oil; (4) 

increased petroleum compounds in tissues; and (5) impaired health (e.g., immunosuppression) (Harvey 

and Dahlheim, 1994). Potential mechanisms for long-term injury include (1) initial sublethal exposure to 

oil causing pathological damage; (2) continued exposure to hydrocarbons persisting in the environment, 

either directly or through ingestion of contaminated prey; and (3) altered availability of prey as a result of 

the spill (Ballachey et al., 1994). Chronic effects may include (1) change in distribution and abundance 

because of reduced prey resources or increased mortality rates, (2) change in age structure in the breeding 

stock because certain year-classes were impacted more by an oil spill, (3) decreased reproductive success, 

and (4) increased rate of disease or neurological problems from exposure to oil (Harvey and Dahlheim, 

1994). 

Clearly, the vitality or productivity of some marine mammals can suffer long-term impacts from oil 

spills, but the evidence for cetaceans being among this affected population has not been convincingly 

established. There is, however, substantial circumstantial evidence based on effects documented in other 

marine mammals that harmful effects from contact between spilled oil and individual whales or dolphins 

can be reasonably expected. Contact between marine mammals and spilled oil is unlikely, and the 

duration of this contact with mobile animals in the open ocean is expected to be very brief. Effects on 

marine mammal populations are expected to be insignificant. 

Conclusion 

The proposed Phoenix Project is expected to have little impact on the vitality of any marine mammal 

species or productivity of any population endemic to the northern GOM. No deaths would be expected 

from direct exposure to spilled oil or to chronic long-term effects caused by contact with spilled oil. 

Although interaction between marine mammals and a weathered oil spill is possible, sublethal effects 

would be the likely result. Collisions between service vessels and marine mammals would be extremely 

rare, but they could be lethal or crippling if realized. The MMS’s regulations and NTL’s are designed to 

reduce the possibility of collisions. There is no conclusive evidence as to whether or not anthropogenic 

noise in the water has caused displacements of marine mammal populations or is injurious to the vitality 

of individuals. Marine mammals could be injured or killed by eating indigestible debris or plastic items 

originating from the proposed development activities, but the likelihood of such an encounter is very 

small. Marine mammal populations are not expected to be adversely impacted by routine discharges due 

to current regulations and guidelines, and rapid dilution. 

3.2.2.2.3. Cumulative Analysis 

Cumulative impacts on marine mammals include (1) water quality degradation from oil, fuel, and 

material spills, high nutrient loads, high turbidity, high BOD, urban runoff, industrial discharges, 

pathogens, and upriver contaminants; (2) noise in the water from infrastructure, vessels, and facility 

removal; (3) vessel traffic and collision hazard; (4) seismic surveying; and (5) trash and debris. Non-OCS 

activity that contributes to cumulative impacts includes the same impact-producing factors from OCS 

activity, but which arise from other industrial, commercial, or recreational activity. Marine mammal 

deaths attributable to non-OCS activity, such as commercial fishing, would be much greater than any 

caused by OCS activity. 

Of these effects, the potential for collision between marine mammals and service vessels probably 

represents the greatest potential for adverse cumulative impacts on marine mammals over the 5-year 

exploration and production cycle. This judgment is made because collisions between large vessels and 

cetaceans, though rare events, typically results in crippling injuries or death. Marine mammals could be 

injured or killed from ensnarement in or consumption of marine debris, particularly plastic items, lost 

from OCS structures and service vessels. Few deaths would be expected from chance collisions between 

marine mammals and OCS service vessels, ingestion of debris such as plastic material, and pathogens. 

Oil spills and associated slicks of any size are infrequent events, but if they do occur they have a very 

small potential to contact marine mammals. Sublethal effects could occur with exposure of marine 

mammals to a weathered oil slick. Disturbance (noise from vessel traffic and drilling operations, etc.) 
37 

and/or exposure to platform discharges may cause sublethal effects, may stress animals and weaken their 

immune systems, and may make them more vulnerable to parasites and diseases. 

The net result of any disturbance would be dependent upon the size and percentage of the population 

affected, ecological importance of the disturbed area, environmental and biological parameters that 

influence an animal’s sensitivity to disturbance and stress, and the accommodation time in response to 

prolonged disturbance (Geraci and St. Aubin, 1980). 

3.2.2.3. Sea Turtles 

3.2.2.3.1. Description 

Five species of sea turtles are found in the waters of the GOM: green, leatherback, hawksbill, 

Kemp’s ridley, and loggerhead. All are protected under the ESA, and all except the loggerhead turtle 

(threatened) are listed as endangered. Detailed information on each listed sea turtles species can be found 

in Chapter 3.2.4 of the Multisale EIS (USDOI, MMS, 2007) and is hereby incorporated by reference into 

this PEA; a brief summay follows. Sea turtles are long-lived, slow-reproducing animals that spend nearly 

all of their lives in the water. Females must emerge periodically from the ocean to nest on beaches. It is 

generally believed that all sea turtle species spend their first few years in pelagic waters, occurring in 

driftlines and convergence zones (in Sargassum rafts) where they find refuge and food in items that 

accumulate in surface circulation features (Carr and Caldwell, 1956; Carr, 1987). Genetic analysis of sea 

turtles has revealed in recent years that discrete, non-interbreeding stocks of sea turtles make up 

“worldwide extensive ranges” of the various species. 

Adult turtles are apparently less abundant in the deeper waters of the Gulf than they are in waters less 

than 27-50 m (80-160 ft) deep (NRC, 1990) and more abundant in the northeastern Gulf than in the 

northwestern Gulf (Thompson, 1988). Sea turtle abundance appears to increase dramatically east of 

Mobile Bay (Davis et al., 2000). Factors such as water depth and turbidity, bottom sediment type, 

salinity, and prey availability may account for this. In the offshore Gulf, sea turtle distribution has been 

linked to zones of convergence. 

Information on each turtle species can be found in Chapter 3.2.4 and Table 3-5 of the Multisale EIS 

(USDOI, MMS, 2007) and is hereby incorporated by reference into this PEA. 

3.2.2.3.2. Impact Analysis 

The impact-producing factors associated with exploration of the Phoenix Project that could affect 

loggerhead, Kemp’s ridley, hawksbill, green, and leatherback turtles, (all listed as endangered or 

threatened species) include (1) noise from helicopter, platform, and vessel traffic; (2) possible collisions 

with service vessels; (3) brightly-lit structures; (4) project-related trash and debris; (5) oil spills and spillresponse activities; and (6) water-quality degradation from platform effluents. Chapters 4.2.1.1.6 and 

4.2.2.1.6 of the Multisale EIS (USDOI, MMS, 2007) contain a discussion of impacts from OCS activity 

and are hereby incorporated by reference into this PEA. 

Operations 

The noise from helicopter operation can elicit a startle response and can interrupt sea turtles while 

resting, feeding, breeding, or migrating. The proposed action is expected to have three helicopter 

roundtrips per week, as needed. These occurrences would be temporary and pass within seconds. There 

are no published systematic studies about the reactions of sea turtles to aircraft overflights, and anecdotal 

reports are scarce. Sea turtles spend more than 70 percent of their time underwater, but it is assumed that 

sea turtles can hear helicopter noise at or near the surface and that unexpected noise may cause animals to 

alter their activity (Advanced Research Projects Agency, 1995). There is evidence suggesting that turtles 

may be receptive to low-frequency sounds, which is the level where most industrial noise energy is 

concentrated. Atmospheric noise inputs, however, are negligible relative to other sources of noise that are 

propagated in water (e.g., platform or drill rig operations and vessel traffic). It is unlikely that sea turtles 

would be adversely affected by routine helicopter traffic operating at prescribed altitudes. 

Brightly-lit, offshore drilling rigs and platforms present a potential distraction to hatchlings (Owens, 

1983). Hatchlings are known to be attracted to light (Raymond, 1984; Witherington and Martin, 1996; 

Witherington, 1997) and could be expected to orient toward lighted offshore facilities (Chan and Liew, 
38 

1988). If this occurs, hatchling predation would increase dramatically since large birds and predacious 

fish also congregate around the platforms (Owens, 1983; Witherington and Martin, 1996). The very short 

duration of the light attraction for hatchlings, however, would indicate that this is a risk only for facilities 

very close to nesting beaches. 

Many types of materials, including plastic wrapping materials, end up as solid waste during 

exploration operations. Some of this material could be accidentally lost overboard where sea turtles can 

consume it. The result of ingesting materials lost overboard could be lethal. Leatherback turtles are 

known to mistake plastics for jellyfish and may be more vulnerable to gastrointestinal blockage than other 

sea turtle species. The probability of a sea turtle encountering trash that appears edible is probably very 

low. Sea turtles could also become entangled or suffer crippling injuries from debris that is lost by 

service vessels. Disposal of solid wastes offshore takes place in covered bins that are warehoused in a 

secure area on the platform, whereupon the bins are returned to shore for landfill disposal by a service 

vessel for landfill disposal. 

Service vessels present a collision hazard to sea turtles. The Phoenix Project is expected to require 

two supply-vessel and crew-vessel roundtrips per week. As additional projects are pursued by industry in 

the area, increased ship traffic levels could increase the probability of collisions between ships and sea 

turtles, resulting in injury or death to some animals. 

Accidental Events 

Spills that occur from the Phoenix Project activities would be few (if any) if they did occur. When an 

oil spill occurs, the severity of effects and the extent of damage to sea turtles are affected by (1) 

geographic location, (2) hydrocarbon type, (3) duration of contact, (4) weathering state of a slick, (5) 

impact area, (6) oceanographic and meteorological conditions, (7) season, and (8) growth stage of the 

animal (NRC, 1985). All sea turtle species and life stages are vulnerable to the harmful effects of oil 

through direct contact or by fouling of their habitats and food. 

No deaths would be expected from direct exposure to spilled oil or to chronic long-term effects. 

Several potential mechanisms for long-term impacts may be (1) sublethal initial exposure to oil, causing 

pathological damage and weakening of body systems or inhibiting reproductive success; (2) chronic 

exposure to residual hydrocarbons persisting in the environment or through ingestion of contaminated 

prey; and (3) altered prey availability as a result of the spill. Turtles may be temporarily displaced from 

areas impacted by spills. Because sea turtle habitat in the Gulf includes coastal and oceanic waters, as 

well as numerous beaches in the region, sea turtles could be impacted by accidental spills from vessels 

supporting the proposed action that are in transit near these environments. Although there is 

documentation of the harmful effects of acute exposure to spilled oil, the effects of chronic exposure are 

less certain and are largely inferred. An interaction between sea turtles at sea and spilled oil are unlikely 

to be realized. Contact between sea turtles and spilled oil is very unlikely, and the duration of this contact 

with mobile animals in the open ocean would be very brief. Adverse effects on sea turtle populations are 

expected to be insignificant. 

Oil-spill-response activities, such as beach sand removal, can adversely affect sea turtles. Vehicular 

and vessel traffic during spill-response actions in sensitive habitats during nesting season can occur. 

Harm to sea turtles is expected to be minimal because of the very low probability of contact between oil 

and these areas and protective spill remediation procedures. Increased human presence in nesting habitats 

could alter behavior of turtles, reduce their distribution, or cause them to move to less favorable areas, 

making them more vulnerable to various physiologic and toxic effects. 

Conclusion 

The proposed Phoenix Project is expected to have little impact on the vitality of any sea turtle species 

or productivity of any population endemic to the northern GOM. A sublethal impact to sea turtle 

individuals exposed to a weathered oil slick is the most likely result. There is no conclusive evidence 

whether or not anthropogenic noise in the water has caused displacements of sea turtle populations or is 

injurious to the vitality of individuals. Collisions between service vessels and sea turtles would be rare, 

but they could be lethal if realized. Sea turtles could be injured or killed by eating indigestible debris or 

plastic items originating from Phoenix activities, but the likelihood of such an encounter is very small. 
39 

3.2.2.3.3. Cumulative Analysis 

Cumulative impacts on sea turtles and their habitats include (1) water quality degradation from oil, 

fuel, and other chemical spills, high nutrient loads, high turbidity, urban runoff, industrial discharges, 

pathogens, and upriver contaminants; (2) habitat loss or degradation; (3) infrastructure and vessel noise, 

lighting, and removal; (4) vessel traffic and collision hazard; (5) trash and debris; and (6) natural 

phenomena such as sea-level rise, subsidence, and storms and hurricanes. Non-OCS activity that 

contributes to cumulative impacts include commercial and recreational fishing that kill or injure turtles by 

accident, beach lighting, and entrainment in power plant intakes. The cumulative impacts from the major 

impact-producing factors on sea turtles would be dominantly sublethal, primarily behavioral changes, 

temporary disturbances, or displacement of localized groups, and rarely lethal. Turtle deaths attributable 

to non-OCS activity are expected to be greater than any caused by OCS activity. 

Of these effects, dislocation from preferred beach-nesting habitats or destruction of these habitats 

probably represents the greatest potential for adverse cumulative impacts on sea turtles over the 5-year 

exploration and production cycle. The Phoenix Project is far from shoreline nesting habitat, and any 

bright lighting on the site should have no effect on sea turtle hatchlings. 

Deaths due to explosive structure-removal operations should not take place or should be extremely 

rare with the explosive removal mitigations required by MMS. Underwater noise from platforms or 

service boats may disrupt normal activities and may cause physiological stress, causing turtles to become 

more susceptible to disease or predation. Collision hazards from service vessels would be expected to 

decrease because of mitigations put into place by MMS. 

There are prohibitions on discarding trash or debris from project activity at sea. Sea turtles could be 

injured or killed from ensnarement in or consumption of marine debris, particularly plastic items, lost 

from OCS structures and service vessels. 

Oil spills, chemical dispersants, and spill-response activities on sensitive nesting coastlines are 

potential hazards that may adversely affect sea turtles or the reproductive success of populations. Contact 

with and consumption of oil and oil-contaminated prey may seriously affect sea turtles. Large spills are 

extremely rare events, and for this reason no contact or interaction is expected between turtles and freshly 

spilled oil. Incidental contact with degraded or weathered oil may be expected between turtles that 

inhabit or transit through the Phoenix Project area. The effects from contact with spilled oil in a 

weathered slick would be sublethal behavioral changes. 

The incremental contribution of the proposed Phoenix Project to the cumulative impacts would be 

negligible. The effects of the most likely impacts, such as the physical presence and operation of the DP 

semisubmersible drilling rig, or noise from the drilling rig, helicopters, and service-vessel traffic, would 

only be expected to modify the behavior of turtles that come into contact with these project facilities. 

3.2.2.4. Essential Fish Habitat and Fish Resources 

3.2.2.4.1. Description 

The description of essential fish habitat (EFH) and fish resources in this deep Gulf of Mexico region 

can be found in Chapter 3.2.8 of the Multisale EIS (USDOI, MMS, 2007). The following information is a 

brief summary of the description that is hereby incorporated by reference from the Multisale EIS. 

Healthy fish resources and fishery stocks depend on EFH—waters and substrate necessary to fish for 

spawning, breeding, feeding, and growth to maturity. The most recent Generic Amendment to all fishery 

management plans (GMFMC, 2005) reduced the extent of EFH relative to the 1998 Generic Amendment 

by removing EFH description and identification from waters between 100 fathoms (183 m or 600 ft) and 

the seaward limit of the Exclusive Economic Zone (as deep as 3,200 m or 10,499 ft). However, the 

habitats most important to managed species (i.e., those shallower than 100 fathoms (183 m or 600 ft)) will 

still be designated as EFH, and so the great majority of benefits to the biological environment will remain. 

The benthic fish populations of Green Canyon Blocks 236 and 237 are expected to be low in density 

and restricted to species that live at water depths below 500 m. No benthic species in these blocks are 

included in any fishery management plan and description of EFH. Discussion of other ecological groups 

of fishes, including oceanic pelagics and mesopelagics, can be found in Chapter 3.2.8.2 of the Multisale 

EIS (USDOI, MMS, 2007). The EFH of Green Canyon Blocks 236 and 237 does retain EFH designation 

for some specific species, including many highly migratory species such as tunas, swordfish, and sailfish. 
40 

In consideration of existing mitigation measures, lease stipulations, and a submitted EFH Assessment 

document, MMS entered into a Programmatic Consultation agreement with NMFS on July 1, 1999, for 

petroleum development activities in the CPA and WPA. This agreement was extended into that portion 

of the EPA known as the Sale 181 Area. Most of the Sale 181 Area is now designated part of the CPA. 

The NMFS concluded EFH consultation with the MMS on the Multisale EIS (USDOI, MMS, 2007) 

through a letter dated December 21, 2006, and concurred with all activities described, with no additional 

conservation recommendations beyond those followed routinely by MMS. This consultation also 

includes Green Canyon Blocks 236 and 237 as well as all of Grid 9. 

It is understood that all previously accepted EFH Conservation Recommendations provided by NMFS 

in the past will be continued. There have been six additional EFH conservation recommendations 

provided by NMFS in addition to standard MMS policies (USDOI, MMS, 2007; Chapter 3.2.8.2). The 

MMS has accepted and adopted these six additional EFH conservation recommendations. 

3.2.2.4.2. Impact Analysis 

The impact-producing factors associated with the drilling of additional wells in the Phoenix Project in 

Green Canyon Blocks 236 and 237 that could affect EFH and fish resources include (1) coastal and 

marine environmental degradation, (2) presence of a DP semisubmersible drill rig, (3) temporary 

discharge of drilling cuttings and associated drilling fluids, and (4) blowouts. Chapters 4.2.1.1.8, 

4.2.2.1.10, and 4.4.10 of the Multisale EIS (USDOI, MMS, 2007) contain a discussion of impacts from 

OCS activity and are hereby incorporated by reference into this PEA. 

Drilling fluids and cuttings will be discharged offshore to contribute to localized temporary marine 

environmental degradation. Drilling operations are restricted in time, and pelagic species in the area 

could easily avoid discharge plumes. Routine discharges from the DP drilling rig would be highly diluted 

in the open marine environment. 

The presence of the DP drilling rig will temporarily act as a fish attracting device for a short period of 

time. The anchoring of the FPU is not expected to have any significant impacts on the mud bottom but 

this structure will act as a fish attracting device for an extended period of time. 

Accidental blowouts with associated hydrocarbons also have the potential to affect fish resources and 

EFH, but there is no evidence that fish or EFH in the Gulf have been adversely affected on a regional 

population level by spills or chronic contamination. There is less than a 0.5 percent chance of a spill ≥

1,000 bbl occurring and contacting shoreline resources as a result of the proposed Phoenix activities. Fish 

resources can be affected by oil-spill components that become dissolved, dissipated, and dispersed in the 

water, and by oil that adheres to particulate matter and sinks into sediment. These effects degrade water 

and substrate quality, but the impacts are temporary and recoverable. Adult fish will, for the most part, 

avoid the oil (Malins et al., 1982; NRC, 1985, 2003; Baker et al., 1991). Impacts of oil spills on adult fish 

have generally been thought to be minimal. Additional discussion of the impacts of oil on fish and fish 

eggs and larvae can be found in Chapter 4.4.10. of the Multisale EIS (USDOI, MMS, 2007). 

In order for an oil spill to affect fish resources at the population level, it would have to be very large 

and correspond to an area of highly concentrated eggs and larvae. The oil would also have to disperse 

from the site of a blowout into the water column at levels high enough to cause toxic effects. Given the 

potential for a blowout, none of these events are likely. 

Conclusion 

The proposed Phoenix Project, including the drilling of six new wells and the installation of an FPU, 

is expected to have little impact on any coastal or marine fish, EFH, or commercial fisheries endemic to 

the northern GOM. If a blowout occurred, plankton, fish eggs, or larvae would suffer mortality in areas 

where their numbers are concentrated in the upper few meters or feet of water and where oil 

concentrations are high enough, assuming any oil reached the surface from the bottom. Specific effects 

from oil spills would depend on several factors, including timing, location, volume and type of oil, 

environmental conditions, and countermeasures used. Losses from larvae and plankton mortality would 

take place in 1-2 years by fish from adjacent unaffected areas that replenish larvae in early phases of the 

life cycle. 
41 

3.2.2.4.3. Cumulative Analysis 

Principal cumulative impacts on EFH and fish resources include (1) degradation of water quality from 

oil, fuel, and material spills, high nutrient loads, high turbidity, high BOD, urban runoff, industrial 

discharges, pathogens, trash and debris, and upriver contaminants; (2) loss of essential habitat important 

for parts of the life cycle, such as healthy estuarine systems, (including wetland loss); and (3) commercial 

overfishing. Many of these sources would have little to no impact on the deepwater area of the Phoenix 

Project. Of these, water quality degradation from multiple inputs and sources, not unique to OCS oil and 

gas activity, represents the greatest potential for cumulative impacts on fish resources and EFH. 

Cumulative water quality degradation attributable to OCS oil and gas activity, such as large oil spills, can 

be dramatic and visually striking when it occurs, but historical data show that that the probability of 

occurrence is extremely low. Planktonic fish eggs and larvae are more susceptible than adults to 

environmental contaminants. 

Hurricanes may impact fish resources by destroying both coastal wetlands and offshore live-bottom 

and reef communities and changing physical characteristics of inshore and offshore ecosystems. As a 

cumulative impacting factor, hurricanes certainly had a substantial impact on Gulf Coast fisheries and 

EFH in 2005. Contrary to initial fears, however, the majority of significant fishery resource impacts were 

to the nearshore coastal and wetlands areas of Texas, Louisiana, Mississippi, and Alabama. Hurricanes 

Katrina and Rita did cause substantial infrastructure (artificial reef EFH) destruction offshore, but the 

actual impacts to fish resources and EFH were not significant. Hurricanes have essentially no cumulative 

impacts in deepwater environments such as Green Canyon Blocks 236 and 237. 

There would be no cumulative impacts to commercial fishing in the Green Canyon Blocks 236 and 

237. There is no commercially viable bottom fishery in the area. 

The incremental contribution of the proposed action’s impacts to the cumulative impact on fish 

resources and EFH is negligible and likely undetectable among the other cumulative impacts. 

3.2.2.5. Gulf Sturgeon 

3.2.2.5.1. Description 

The description of the biology, life history, distribution, and causes for population decline of Gulf 

sturgeon can be found in Chapter 3.2.7.1 of the Multisale EIS (USDOI, MMS, 2007). Designated Gulf 

sturgeon critical habitat occurs in estuarine and riverine locations along the Gulf Coast east of the 

Mississippi River in Louisiana, Mississippi, Alabama, and Florida (USDOI, MMS, 2007; Chapter 

3.2.7.1). Critical habitat is defined as special geographic areas that are essential for the conservation of a 

threatened or endangered species and that may require special management and protection. Designated 

Gulf sturgeon critical habitat is confined to State waters. In addition, there has not been any critical 

habitat designated in coastal or offshore waters west of the Mississippi River. Therefore, there is no 

critical habitat within the proposed action area due to the distance from shore and its westward proximity 

to the Mississippi River. Most activities related to the proposed action will occur in Federal waters 

(temporary structure placement, exploratory drilling, etc); however, critical habitat may be impacted 

directly or indirectly. 

Various Internet sources were examined to determine any recent information regarding Gulf sturgeon 

(Florida Fish and Wildlife Commission, 2007; USDOI, FWS, 2007a and b). No new information was 

discovered from these information sources. 

State and Federal resource agencies were contacted and interviews conducted to investigate any 

recent published or unpublished data that may be available. Current information indicates that there may 

have been some displacement of sturgeon or possibly damage to their habitat in localized areas where the 

forces of Hurricane Katrina were the strongest. The current sampling programs along the coastal Gulf 

South indicate (at least anecdotally) that sturgeon are returning to the areas they occupied prior to the 

hurricane, which may be indicative of a recovery of those areas (Paruka, personal communication, 2007). 

No changes in migratory patterns or blockages of migratory pathways have been noted. In general, the 

researchers noted that the sturgeon are normally found approximately 0.5 mi (0.8 km) from shore between 

the shoreline and the barrier islands with the bulk of the fish located in the CPA between Petit Bois, 

Dauphin, and Chandeleur islands and from Perdido to Panama City as far as Fort Walton Beach (Slack, 

personal communication, 2007; Paruka, personal communication, 2007). 
42 

A Gulf sturgeon population census was conducted in the lower Escambia River from October 10 

through November 5, 2006. This fish collection coincided with the sturgeons’ fall migration from the 

freshwater to marine environment. This study collected 130 fish ranging in size from 1 to 145 pounds 

(lb). Large fish (>99 lb) accounted for 10 percent of the catch, which is less than in 2003 where the same 

class comprised 19 percent of the catch (Paruka, personal communication, 2007). The current Gulf 

sturgeon population estimate is 451 fish. The decrease from the estimated 554 fish in 2004 is probably a 

result of the hurricane–induced, degraded water quality. 

At present, NOAA indicates that no changes in critical habitat have occurred, and they are working to 

develop an estimate of sturgeon habitat loss and a habitat suitability index for the species (Bolden, 

personal communication, 2007). Critical habitat is defined as special geographic areas that are essential 

for the conservation of a threatened or endangered species and that may require special management and 

protection. There is also no data indicating that sturgeons are using the deeper Gulf waters. In general, 

mud substrates found in Gulf waters do not support the appropriate benthic food source for Gulf sturgeon. 

Based on the absence of critical habitat, lack of preferred substrate, and water depth in the proposed 

exploration, construction, and well site, there would be minimal to no chance of impacting Gulf sturgeon 

at the Phoenix Project site. 

3.2.2.5.2. Impact Analysis 

A detailed impact analysis of the routine, accidental and cumulative impacts of the proposed action 

on Gulf sturgeon can be found in Chapters 4.2.2.1.9.1, 4.4.9.1, and 4.5.9.1 of the Multisale EIS (USDOI, 

MMS, 2007). 

Impact-producing factors associated with routine exploration activities proposed here could include 

disturbance of sea bottom with drilling, structure placement, and degradation of estuarine and marine 

water quality by nonpoint runoff from marine OCS-related facilities, oil or condensate spills associated 

with a well blowout, vessel traffic, and pipeline installation. Due to the distance of the proposed activity 

from the nearest shoreline (91 mi; 146 km) and the critical habitat, it is unlikely that offshore spills or 

effluents will impact Gulf sturgeon habitat. The dilution and low toxicity of this pollution is expected to 

result in negligible impact of the proposed action on Gulf sturgeon if it does reach the nearshore waters. 

Vessel traffic will generally only pose a risk to Gulf sturgeon when leaving and returning to port; 

however, Port Fourchon is outside of this habitat. Major navigation channels are excluded from critical 

habitat. The Gulf sturgeon’s characteristics of bottom-feeding and general avoidance of disturbance make 

the probability of vessel strike extremely remote. State waters east of the mouth of the Mississippi River 

have the greatest potential for Gulf sturgeon occurrence and are also the location of its critical habitat. 

Most of the activities related to the proposed action will occur in Federal waters (e.g., structure 

placement, drilling, use of existing pipelines, etc.) west of the Mississippi River; therefore, while the 

potential for direct impact to the sturgeon or its habitat is minimal to none, some indirect impacts could 

occur but are unlikely. 

The most likely accidental impact-producing factor on Gulf sturgeon resulting from the proposed 

action is an oil spill resulting from a well blowout. Due to the distance of the exploration activity from 

shore, any oil reaching those areas would be sufficiently weathered to have a minimal toxic effect on the 

sturgeon. No long-term effects are expected on the size or productivity of any distinct, interbreeding, 

Gulf sturgeon population stock in the GOM. No coastal spills or blowouts ≥1,000 bbl have occurred from 

OCS facilities during the historical period of record from 1985 to 1999 (Appendix B). 

Gulf sturgeon can take up oil by direct ingestion, ingestion of oiled prey, or the absorption of 

dissolved petroleum components across gill mucus and gill epithelium; however, liver enzymes of adult 

fish oxidize soluble hydrocarbons into compounds that are excreted in the urine (Spies et al., 1982), 

without lethal effects. If behavioral studies of other fish species provide a guideline (Farr et al., 1995; 

Nevissi and Nakatani, 1990), adult sturgeon are likely to actively avoid an oil spill. Based on the OilSpill Risk Analysis results (Appendix B), there is a <0.5 percent combined probability of an oil spill 

reaching coastal waters where Gulf sturgeons or their critical habitat are found. 

Conclusion 

The proposed Phoenix Project is expected to have little impact on Gulf sturgeon. Based on the recent 

analysis of spill risk from Phoenix-related activities (Appendix B), there is a <0.5 percent chance of an 

oil spill reaching coastal waters where Gulf sturgeons or their critical habitat are found. Due to the 
43 

distance of the proposed activities from shore (91 mi; 146 km), any oil reaching those areas would be 

sufficiently weathered to have the minimal toxic effect on the sturgeon. The greatest danger to the critical 

habitat and the Gulf sturgeon would be from nearshore, shuttle-tanker collisions or offloading spills 

(USDOI, MMS, 2001). The historical data from 1985 to 1999 show no spills from either of these types of 

operations has occurred (Appendix B). 

3.2.2.5.3. Cumulative Analysis 

The Gulf sturgeon and its critical habitat can be cumulatively impacted by activities such as oil spills, 

alteration and destruction of habitat, degradation of water quality, channel construction, dredging and 

filling operations, flood control activities, natural catastrophes, commercial fishing, and water 

management responses to drought conditions. The effects from contact with spilled oil will be sublethal 

and last for less than 1 month. 

Non-OCS operations, such as dredge-and-fill activities and natural catastrophes, indirectly impact 

Gulf sturgeon through the loss of spawning and nursery habitat. Dredge-and-fill activities occur 

throughout the nearshore areas of the United States. The activities range in scope from propeller dredging 

(scarring) by recreational boats to large-scale navigation dredging and fill for land reclamation. 

Commercial fishing techniques such as trawling, gill netting, or purse seining, when practiced 

nonselectively, may impact species other than the target species due to incidental catch. Ongoing inshore 

alterations such as in stream sand and gravel mining, channelization, dredge-and-fill operations, water 

diversion, and dams, combined with the construction of coastal restoration projects in nearshore waters, 

will continue to impact sturgeon habitat. If any of the above were to occur and result in damage to Gulf 

sturgeon critical habitat, it is expected that the Gulf sturgeon will experience a decline in population sizes 

and a displacement from their current distribution that will last more than one generation. 

At present, there is no Gulf sturgeon critical habitat identified west of the Mississippi River in the 

planning area for the proposed Phoenix Project in Green Canyon. Therefore, the incremental contribution 

of the proposed action to the cumulative impact is negligible because, even if the sturgeon should come in 

of contact with project-specific oil spills, the dosage is expected to be sublethal and last less than 1 month. 

The NMFS completed consultation as specified under Section 7 of the ESA on the effects of the 

5-year OCS Program (2007-2012) in the CPA and WPA. A Biological Opinion was rendered on June 29, 

2007, concurring with MMS that the proposed actions would not adversely impact the endangered Gulf 

sturgeon or its critical habitat and that no additional mitigation actions other than those already identified 

and in place would be necessary. 

3.2.2.6. Coastal and Marine Birds 

3.2.2.6.1. Description 

Information on coastal and marine birds can be found in Chapter 3.2.6 of the Multisale EIS (USDOI, 

MMS, 2007) and is hereby incorporated by reference into this PEA and is briefly summarized below. 

The offshore waters, coastal beaches, and contiguous wetlands of the northeastern GOM are populated by 

both resident and migratory species of coastal and marine birds. Many species are mostly pelagic and are 

rarely sighted nearshore. Fidelity to nesting sites varies from year to year along the Gulf Coast (Martin 

and Lester, 1991). Birds may abandon sites along the northern Gulf Coast because of altered habitat and 

excessive human disturbance. 

Seabirds are a diverse group of birds that spend much of their lives on or over saltwater. Species 

diversity and overall abundance is highest in the spring and summer and lowest in the fall and winter. 

Four ecological categories of seabirds have been documented in the deepwater areas of the Gulf: summer 

migrants (e.g., shearwaters, storm petrels, and boobies); summer residents that breed in the Gulf (e.g., 

sooty, least, and sandwich tern, and frigate birds); winter residents (e.g., gannets, gulls, and jaegers); and 

permanent resident species (e.g., laughing gulls and royal and bridled terns) (Hess and Ribic, 2000). 

Collectively, they live far from land most of the year, roosting on the water surface, except at breeding 

time when they return to nesting areas along coastlines (Terres, 1991). Seabirds typically aggregate in 

social groups called colonies; the degree of colony formation varies between species (Parnell et al., 1988). 

They also tend to associate with various oceanic conditions including specific sea-surface temperatures, 

salinities, areas of high planktonic productivity, or current activity. Seabirds obtain their food from the 

sea with a variety of behaviors including piracy, scavenging, dipping, plunging, and surface seizing. 
44 

Listed Species of Coastal and Marine Birds 

The following coastal and marine bird species that inhabit or frequent the northern GOM coastal areas 

are protected under the ESA as either endangered or threatened: piping plover, whooping crane, brown 

pelican, least tern, and bald eagle. 

Piping Plover 

The piping plover (Charadrius melodus) is a migratory shorebird that is native to North America. 

The piping plover was designated as threatened in December 1985 over its range in the Gulf Coast States. 

It breeds on the northern Great Plains (especially in open flats along the Missouri River), in the Great 

Lakes, and along the Atlantic Coast (Newfoundland to North Carolina). It winters on the Atlantic and 

Gulf Coasts from North Carolina to Mexico and in the Bahamas West Indies. Hypothetically, plovers 

may have a preferred prey base and/or the substrate coloration provides protection from aerial predators 

due to camouflage by color matching in specific wintering habitat. Such areas include coastal sand flats 

and mud flats in proximity to large inlets or passes, which may attract the largest concentrations of piping 

plovers (Nicholls and Baldassarre, 1990). Similarly, nesting habitat in the north includes open flats. This 

species remains in a precarious state given its low population numbers, sparse distribution, and continued 

threats to habitat throughout its range. 

Critical habitat is specially managed or protected only in the case of a Federal action. On July 10, 

2001, critical habitat was designated for the wintering population of piping plover in 146 areas along 

approximately 2,700 mi (4,344 km) of the coasts of North Carolina, South Carolina, Georgia, Florida, 

Alabama, Louisiana, and Texas (USDOI, FWS, 2001). 

Critical habitat identifies specific areas that are essential to the conservation of a listed species and 

that may require special management consideration or protection. The primary constituent needs for the 

piping plover are those habitat components that are essential for the primary biological needs of foraging, 

shelter, and roosting. 

Whooping Crane 

The whooping crane (Grus americana) is an omnivorous, wading bird. It formerly ranged from 

summer breeding grounds within the central Canadian provinces and northern prairie states to southern 

coastal wintering grounds from central Mexico to the Carolinas (Bent, 1926). Whooping cranes currently 

exist in three wild populations and at five captive locations (USDOI, FWS, 1994). The only selfsustaining wild population nests in Canada’s Northwest Territory and adjacent areas of Alberta and 

winters in coastal marshes and estuarine habitats along the Texas Gulf Coast. 

Brown Pelican 

The brown pelican (Pelicanus occidentalis) remains endangered (Federal Register, 1985) in 

Louisiana and Mississippi, where it inhabits the coastal areas. It is not federally listed in Florida; rather it 

is a State species of special concern. It feeds entirely upon fishes captured in coastal waters. 

Organochlorine pesticide pollution contributed to the endangerment of the brown pelican. In recent years, 

there has been a marked increase in brown pelican populations along its entire former range. The 

populations of brown pelicans and their habitat in Alabama, Florida, Georgia, North and South Carolina, 

and points northward along the Atlantic Coast were removed from the endangered species list in 1985. 

The Louisiana Dept. of Wildlife and Fisheries submitted a request to FWS in March 1994 to officially 

remove the brown pelican from the endangered species list in Louisiana (Louisiana Dept. of Wildlife and 

Fisheries, 1994). Ten thousand nests and an estimated 25,000 adults were found in a recent Louisiana 

survey (Patrick, personal communication, 1997). 

Least Tern 

The teast tern is not considered federally endangered or threatened in coastal areas within 50 mi 

(80 km) of the Gulf (Patrick, personal communication, 1997). Only the interior nesting colonies are 

endangered. 
45 

Bald Eagle 

On June 28, 2007, FWS announced the removal of the bald eagle from the list of threatened and 

endangered species (USDOI, FWS, 2007c). The FWS will work with State wildlife agencies to monitor 

eagles for at least 5 years. The bald eagle will continue to be protected by the Bald and Golden Eagle 

Protection Act and the Migratory Bird Treaty Act. 

3.2.2.6.2. Impact Analysis 

The impact-producing factors associated with development and production of the Phoenix Project in 

Green Canyon Blocks 236 and 237 that could affect coastal and marine birds include (1) air emissions, (2) 

helicopter and service-vessel traffic and noise, (3) lights from the floating production unit, (4) oil spills 

and oil-spill-response activities, and (5) trash and debris from the floating production unit and service 

vessels. These impact-producing factors apply to nonthreatened or nonendangered bird species as well as 

those that are listed. Chapters 4.2.1.1.7 and 4.2.2.1.8 of the Multisale EIS (USDOI, MMS, 2007) contain 

a discussion of impacts from OCS activity and are hereby incorporated by reference into this PEA, and a 

brief summary follows. 

Operations 

The major effects of air pollution on birds include direct mortality, debilitating injury, disease, 

physiological stress, anemia, hypocalcemic condition, bioaccumulation of air pollutants with associated 

decrease in resistance to debilitating factors, and population declines (Newman, 1979). Contamination of 

birds or other wildlife by air emissions can occur in three ways: inhalation, absorption, and ingestion. 

Air emissions from the Phoenix Project will have a negligible effect on coastal or marine birds that 

inhabit or transit the offshore OCS area in Grid 9. Emissions from activities associated with the proposed 

action would be expected to have minimal effects on offshore air quality because of the prevailing 

atmospheric conditions, emission heights, and pollutant concentrations. Because of distance to the 

shoreline, no effects would be expected on onshore air quality that could be deleterious to birds. 

Helicopter and service-vessel traffic related to the proposed action could sporadically disturb birds 

while feeding, resting, nesting, or reproducing, or cause them to abandon nests or preferred habitat 

onshore. The Federal Aviation Administration (USDOT, FAA, 2004) and corporate helicopter policy 

state that the specified minimum altitude is 610 m (2,000 ft) when flying over populated areas and 

biologically sensitive areas such as wildlife refuges and national parks. Bird populations inhabiting the 

helicopter descent corridor at the Port Fourchon onshore service base could be disturbed. Service vessels 

would use selected transit corridors and adhere to protocol established by USCG for reduced vessel 

speeds within these inland areas. The effects of routine service-vessel traffic on coastal and marine birds 

would be negligible. 

No drilling fluids and cuttings would be discharged offshore to possibly contact birds on the water or 

their food supplies. Produced water is expected to be discharged at the sea bed, and routine discharges 

from the floating production unit would be highly diluted in the open marine environment. 

Seabirds (e.g., laughing gulls and petrels) may be attracted by lights and structures in the remote 

offshore and may remain to rest and feed in the vicinity of fixed platforms. Coastal and marine birds are 

commonly observed entangled and snared in floating trash and debris. In addition, many species ingest 

small plastic debris, either intentionally or incidentally. Such interactions can lead to serious injury and 

death. The MMS’s operating regulations at 30 CFR 250.300 and NTL 2003-G06, “Marine Trash and 

Debris Awareness and Elimination,” prohibit the disposal of equipment, containers, and other materials 

into offshore waters by lessees. The MARPOL Convention (International Maritime Organization, 2008) 

prohibits the disposal of any plastics at sea or in coastal waters. Due to the low potential for interaction 

between coastal and marine birds and project-related debris, effects would not occur or would have 

negligible impact. 

Accidental Events 

Contact with spilled oil and oil-contaminated prey may be lethal or have serious long-term impacts on 

marine birds. Stress and shock can enhance the effects of exposure to oil. The direct oiling of coastal or 

marine birds in a fresh slick is probably lethal. Contact between birds and a weathered or dissipated slick 
46 

may lead to sublethal effects. Several mechanisms for long-term impacts can be postulated: (1) sublethal 

initial exposure to oil causing pathological damage and weakening of body systems or inhibiting 

reproductive success; (2) chronic exposure to residual hydrocarbons in the environment; (3) ingestion of 

contaminated prey; and (4) altered prey availability resulting from a spill. Ingestion of oil in food 

occurred after the oil from the Exxon Valdez spill had weathered (Hartung, 1995). Final major impacts to 

European shags (Phalacrocorax aristotelis) from the Prestige spill off the coast of Spain probably came a 

year later from a decimated food supply of fish (Velando et al., 2005). 

Pneumonia can occur in oiled birds after they inhale droplets of oil while cleaning their feathers. 

Exposure to oil can cause severe and fatal kidney damage (Frink and Miller, 1995). Ingestion of oils 

might reduce the function of the immune system and reduce resistance to infectious diseases (Leighton, 

1990). Ingested oil may cause toxic destruction of red blood cells and varying degrees of anemia 

(Leighton, 1990). It is not clear which, if any, of the pathological conditions noted in necropsies are 

directly caused by hydrocarbons or are a final effect in a chain of events with oil as the initiating cause 

followed by an intermediate effect of chronic and generalized stress (Clark, 1984). Low levels of oil 

could stress birds by interfering with food detection, feeding impulses, predator avoidance, territory 

definition, homing of migratory species, susceptibility to physiological disorders, disease resistance, 

growth rates, reproduction, and respiration. Recovery would depend on subsequent in-migration of birds 

from nearby feeding, roosting, and nesting habitats. 

The combined probability of a spill occurring in the area of the proposed action and contacting 

coastal bird resources within 3, 10, or 30 days is <0.5 percent. Impacts on bird resources from such a 

spill are expected to be negligible. 

Oil-spill cleanup methods often require heavy traffic on beaches and wetland areas, application of oil 

dispersants and bioremediation chemicals, and the distribution and collection of oil containment booms 

and absorbent material. The presence of humans, along with boats, aircraft, and equipment, could also 

disturb coastal birds after a spill. Investigations have shown that oil dispersant mixtures pose a threat to 

bird reproduction similar to that of oil (Albers, 1979; Albers and Gay, 1982) and may reduce chick 

survival more than exposure to oil alone. Successful dispersal of a spill would generally reduce the 

probability of exposure of coastal birds to oil (Butler et al., 1988). It is possible that changes in the size 

of a breeding population may also be a result of disturbance from increased human activity related to 

cleanup, monitoring, and research efforts (Maccarone and Brzorad, 1994). A relatively recent study states 

that long-term rigorous studies of rehabilitated and released birds of various species relative to unoiled 

birds are needed (Russell et al., 2003). Deterrent or preventative methods such as scaring birds from the 

path of an approaching oil slick or using booms to protect sensitive colonies in an emergency produce 

mixed results, depending on methods (Clark, 1984). Birds may habituate to the scare if it is always 

present. A new method of using unmanned (less expensive) scare techniques uses radar to detect the 

approach of birds. The deterrent device is set off only when birds are detected near a spill (Ronconi et al., 

2004). 

Conclusion 

The proposed Phoenix Project is expected to have little impact on the vitality of any coastal or marine 

birds or productivity of any population endemic to the northern GOM. It is expected that impacts on 

coastal and marine birds would be sublethal, consisting of behavioral changes and temporary disturbances 

or displacement of localized groups. Chronic stress such as digestive distress or occlusion, sublethal 

ingestion, and behavioral changes, however, are often difficult to detect or attribute. Such stresses can 

weaken individuals and make them more susceptible to infection and disease as well as making migratory 

species less fit for migration. Recovery would take place in a period of months to 1 year by the cessation 

of a disturbance and by the influx of birds from nearby feeding, roosting, and nesting habitats that are 

unaffected. Impacts to coastal bird resources from an oil spill in the area of the proposed action have a 

very low probability of occurrence and are therefore expected to be negligible. 

3.2.2.6.3. Cumulative Analysis 

Cumulative impacts on coastal and marine birds include (1) air emissions; (2) water quality 

degradation from oil, fuel, and material spills, high nutrient loads, high turbidity, high BOD, urban runoff, 

industrial discharges, pathogens, and upriver contaminants; (3) habitat loss and shoreline modification 

from construction and development; (4) collisions with aircraft; (5) noise from aircraft and vessels; (6) 
47 

trash and debris; and (7) natural phenomena such as sea-level rise, subsidence, global warming, and 

storms and hurricanes. Non-OCS industrial, commercial, or recreational activities that contribute to these 

cumulative impacts involve the same impact-producing factors as OCS activities. The cumulative 

impacts from the majority of impact-producing factors on coastal and marine birds would be rarely lethal 

and predominantly sublethal, constituting behavioral changes, temporary disturbances, or displacement of 

localized bird groups. 

Industry activity that contributes to habitat modification and destruction includes construction and 

maintenance of pipelines and corridors, and dredging to accommodate deep-draft service vessels used to 

support deepwater projects. Non-OCS activity would include coastal development, shoreline 

modifications, flood control programs, and dredging, which would be done to accommodate international 

shipping and cruise ship traffic. 

Exposure to contaminants or discarded debris will usually cause behavioral changes, temporary 

disturbances, or displacement of localized bird groups. The rates of air and water degradation in coastal 

and marine environments and the amount of shoreline trash and debris is likely to increase slowly in line 

with regional economic and population growth trends. Behavioral changes can be expected as 

competition increases among bird groups for favored habitats. The trash and debris burden on shorelines 

that is attributable to OCS activity is expected to decline because of continuing education programs for 

offshore workers, enforcement of controls for trash produced offshore and on service vessels, and 

industry sponsorship and participation in “beach sweeps” to assay the types of trash found along 

shorelines and remove it. 

Helicopter traffic will increase slightly but will not present an increased collision hazard because 

these occurrences are rare even now. Aircraft or vessel traffic could sporadically disturb feeding, resting, 

or nesting behavior of birds or cause abandonment of preferred habitat. 

Accidental events, such as an oil spill, would cause lethal effects in birds that are heavily oiled. 

Coastal birds can be vulnerable to spills making landfall. Contact with weathered oil or a dissipated slick, 

dispersant chemicals, and spill-response activities in wetlands and other biologically sensitive coastal 

habitats would be expected to cause lethal to sublethal effects to individuals from any or all bird groups 

through ingestion or inhalation of oil, ingestion of oiled prey, or food being unavailable because of a spill. 

Large spills are extremely rare events, and for this reason little or no contact or interaction is expected 

between birds and freshly spilled oil. Incidental contact with degraded or weathered oil could be 

expected between birds that inhabit or migrate through Grid 9 over the next 5 years. 

The incremental contribution of the proposed Phoenix Project to the cumulative impact would be 

negligible because the effects of the most likely impacts, such as the physical presence and operation of 

the platform facility, or noise from helicopters and service-vessel traffic, would only be expected to 

modify the behavior of birds that come into contact with these project facilities. 

The cumulative effects of habitat modification or loss due to onshore commercial, industrial, 

agricultural and residential development (non-OCS related) may cause an eventual decline or alteration in 

species density, composition or distribution of avian species typical of coastal regions over a 5-year 

period. Some of these changes may become permanent, as documented in historical census data, and 

stem from a net decrease in preferred habitat. 

3.3. SOCIOECONOMIC AND HUMAN RESOURCES

3.3.1. Socioeconomic Resources 

Socioeconomic resources in the GOM region are characterized in Chapter 3.3 of the Multisale EIS 

(USDOI, MMS, 2007) and are hereby incorporated by reference into this PEA. Summaries of these 

resources follow and include (1) the impact area for the proposed Phoenix Project, (2) commercial 

fisheries, (3) recreational resources, and (4) archaeological resources. 

3.3.1.1. Socioeconomic Impact Area 

The MMS defines the GOM impact area for population, labor, and employment as that portion of the 

GOM coastal zone whose social and economic well-being (population, labor, and employment) is directly 

or indirectly affected by the OCS oil and gas industry. For this analysis, the coastal impact area consists 

of 132 counties and parishes along the U.S. portion of the GOM. This area includes 42 counties in Texas, 

32 parishes in Louisiana, 7 counties in Mississippi, 8 counties in Alabama, and 43 counties in Florida, 
48 

which are listed in Table 3-17 and illustrated in Figure 3-12 of the Multisale EIS (USDOI, MMS, 2007). 

Thirteen economic impact areas (EIA’s) divide the impact area for analysis purposes and are considered 

in Chapters 3.3.1 and 3.3.2 of the Multisale EIS (USDOI, MMS, 2007) as the economic impact area for 

the proposed Phoenix Project. 

The criteria for including counties and parishes in this impact area are explained in Chapter 3.3.5.1 of 

the Multisale EIS (USDOI, MMS, 2007). This impact area is based on sets of counties (and parishes in 

Louisiana) that have been grouped on the basis of intercounty commuting patterns. The labor market 

area’s (LMA’s) identified by this grouping are commuting zones, as identified by Tolbert and Sizer 

(1996). In their research, Tolbert and Sizer (1996) used journey-to-work data from the 1990 census to 

construct matrices of commuting flows from county to county. A statistical procedure known as 

hierarchical cluster analysis was employed to identify counties that were strongly linked by commuting 

flows. The researchers identified 741 of these commuting zones for the U.S. Twenty-three of these LMA 

areas span the Gulf Coast, from the southern tip of Texas to Miami and the Florida Keys, and comprise 

the 13 MMS-defined EIA’s for the Gulf. 

The socioeconomic resources evaluated in this PEA are limited to that portion of the GOM’s coastal 

zone directly or indirectly affected by activities associated with the Phoenix Project. 

3.3.1.2. Commercial Fisheries 

3.3.1.2.1. Description 

The most recent, complete information on landings and value of fisheries for the U.S. was compiled 

by NOAA Fisheries Service for 2006. These statistics were reviewed in depth by MMS in the 

Supplemental EIS for the addition of the 181 South Area to the CPA (USDOI, MMS, 2008). In 

summary, during 2006, commercial landings of all fisheries in the GOM totaled nearly 1.3 billion pounds, 

valued at over $662 million (USDOC, NMFS, 2007). The GOM provides over 31 percent of the 

commercial fish landings in the continental U.S. (excluding Alaska) on an annual basis. Menhaden was 

the most important GOM species in terms of quantity landed, and shrimp was the most important GOM 

species in terms of value. 

Historically, the deepwater offshore fishery contributes less than 1 percent to the regional total weight 

and value (USDOI, MMS, 2001). Target species can be classified into three groups: (1) epipelagic (open 

waters into which enough light penetrates for photosynthesis) fishes; (2) reef fishes; and (3) invertebrates. 

The Phoenix Project and Green Canyon Bocks 236 and 237 are beyond the normal depth range of 

commercial reef fishes and invertebrates. 

Epipelagic commercial fishes are widespread in the Gulf and assuredly occur in Green Canyon 

Blocks 236 and 237. Oceanic pelagic fishes were not landed in high quantities overall in the Gulf relative 

to other finfish groups. 

3.3.1.2.2. Impact Analysis 

The impact-producing factors associated with the Phoenix Project in Green Canyon Blocks 236 and 

237 that could affect commercial fishing include (1) underwater OCS obstructions, (2) coastal and marine 

environmental degradation, (3) space-use conflicts, (4) temporary discharge of drilling cuttings, and (5) 

blowouts or oil spills. Chapters 4.2.1.1.9, 4.2.2.1.11, and 4.4.10 of the Multisale EIS (USDOI, MMS, 

2007) contain a detailed discussion of impacts from OCS activity and are hereby incorporated by 

reference into this PEA. 

The most likely objectives for commercial fishing would be epipelagic species that are highly mobile 

and have the ability to avoid disturbed areas. This fishery is traditionally pursued using a highly mobile 

longliner fleet. There will be some loss of area available to longline fishing by the installation of the 

Phoenix FPU and DP semisubmersible, and longlines could become entangled in the platform. 

Drilling fluids and cuttings discharged offshore would contribute to localized temporary marine 

environmental degradation. Chronic, low-level contamination of nearshore and open marine 

environments is a persistent and recurring event resulting in frequent but nonlethal physiological irritation 

to those resources that lie within the range of impact. 

Spills that contact coastal bays and estuaries have the greatest potential to affect commercial fishery 

resources by killing large numbers of fish eggs and larvae. If a spill contacts nearshore waters, 

commercially important migratory species could be affected. Although the quantity of commercial 
49 

landings of migratory species in the GOM is comparatively small, these species can be of high value. 

There are no commercially important demersal fish resources in the water depths of Green Canyon 

Blocks 236 and 237. 

 An unlikely blowout or oil spill (≥1,000 bbl) would be recovered offshore, and what is not recovered 

would arrive inshore in a highly weathered and degraded state. The impacts of a spill are discussed in 

detail in Chapter 4.4.10 of the Multisale EIS (USDOI, MMS, 2007). In summary, adult fish must become 

exposed to crude oil for some time, probably on the order of several months, to sustain a dose that causes 

biological damage (Payne et al., 1988). Adult fish also possess some capability for metabolizing oil 

(Spies et al., 1982). Farr et al. (1995) documented an avoidance reaction by fish to waters containing 

dissolved hydrocarbon, and analogous behavior can be expected of commercially important fish. 

Besides the risk of contact from an offshore spill, Louisiana coastal waters could experience a spill 

along pipelines or vessel transit routes and corridors and near ports that support the proposed operations. 

According to USCG, 95 percent of all reported coastal spills each year are <24 bbl, so the great majority 

of coastal spills would likely be small, would disperse quickly, and would have no discernable effect on 

commercial fisheries. The MMS assumes that a degraded petroleum spill from OCS activity will 

occasionally contact and affect nearshore and coastal areas of migratory Gulf fisheries. There is no 

evidence that commercial fisheries in the Gulf have been adversely affected on a regional population level 

by spills or chronic contamination. 

Even if fish resources successfully avoid spills, tainting (oily-tasting fish), public perception of 

tainting, or the potential of tainting commercial catches will prevent fishermen (either voluntarily or 

imposed by regulation) from operating in a spill area. Restrictions on catch could decrease landings 

and/or value for several months. Because the ranges of commercially important fish resources are large, 

Gulf fishermen do not fish in one locale and have responded to past petroleum spills by moving elsewhere 

for a few months without substantial loss of catch or income. The effect of oil spills on commercial 

fishing is expected to have minimal impact on landings, or value of those landings. Potential effects 

caused by the level of activity of the Phoenix Project would be indistinguishable from variations due to 

natural causes. 

Conclusion 

There will be no loss of fishing space because of the physical presence of the structure since it is in an 

area in which longline commercial fishing is currently banned. In addition, there are no commercially 

important demersal species at the water depth of this proposed action. 

The proposed Phoenix Project is expected to have little impact on the productivity of any commercial 

fisheries endemic to the northern GOM. There are no commercial fisheries that are restricted exclusively 

to Green Canyon Blocks 236 and 237. Bottom obstructions are not expected to be an issue because of 

extreme water depths and the lack of commercially important species at these depths. 

Desirable pelagic fish species may also be attracted to the DP semisubmersible drilling rig for the 

temporary period of operations and could briefly improve commercial catches using fishing techniques 

other than longlining. A large oil spill, which is unlikely, might adversely affect commercial resources in 

the general area, but Gulf fishing fleets can respond by temporarily moving the location of their 

operations. 

3.3.1.2.3. Cumulative Analysis 

Cumulative impacts on commercial fisheries are the same as on fish resources in general and on EFH 

as discussed in detail in Chapter 4.5.10 of the Multisale EIS (USDOI, MMS, 2007). These impacts 

include (1) degradation of water quality from oil, fuel, and material spills, high nutrient loads, high 

turbidity, high BOD, urban runoff, industrial discharges, pathogens, trash and debris, and upriver 

contaminants; (2) loss of essential habitat important for parts of a fishery’s life cycle, such as healthy 

estuarine systems (including wetland loss); and (3) overfishing. 

Impact-producing factors of the cumulative scenario that are expected to substantially affect 

commercial fishing include commercial and recreational fishing techniques or practices, hurricanes, 

installation of production platforms in the future, additional underwater OCS obstructions, seismic 

surveys, petroleum spills, subsurface blowouts, and offshore discharges of drilling muds and produced 

waters. At the estimated level of cumulative impact, the resultant influence on commercial fishing, 
50 

landings, and value of those landings is not expected to be substantial due to the remote location of Green 

Canyon Blocks 236 and 237 and extreme water depths. 

The incremental contribution of the proposed action’s impacts to the cumulative impact on 

commercial fishing is negligible and likely undetectable among the other cumulative impacts. 

3.3.1.3. Recreational Resources 

3.3.1.3.1. Description 

Chapters 3.3.2 and 3.3.3 of the Multisale EIS (USDOI, MMS, 2007) contains a detailed description of 

recreational resources and is hereby incorporated by reference into this PEA, and a brief summary 

follows. The northern GOM coastal zone is one of the major recreational regions of the U.S., particularly 

in connection with marine fishing and beach-related activities. The shorefronts along the Gulf Coasts of 

Florida, Alabama, Mississippi, Louisiana, and Texas offer a diversity of natural and developed landscapes 

and seascapes. The coastal beaches, barrier islands, estuarine bays and sounds, river deltas, and tidal 

marshes are extensively and intensively used for recreational activity by residents of the Gulf South and 

tourists from throughout the Nation, as well as from foreign countries. Publicly owned and administered 

areas (such as national seashores, parks, beaches, and wildlife lands), as well as specially designated 

preservation areas (such as historic and natural sites and landmarks, wilderness areas, wildlife sanctuaries, 

and scenic rivers), attract residents and visitors throughout the year. Commercial and private recreational 

facilities and establishments (such as resorts, marinas, amusement parks, and ornamental gardens) also 

serve as primary interest areas and support services for people who seek enjoyment from the recreational 

resources associated with the GOM. The Multisale EIS was issued prior (2002) to the impacts of 

Hurricanes Katrina and Rita (2005), which caused extensive adverse impact to tourism and recreation 

throughout the Gulf. It will likely take years for tourism and recreation to return to pre-hurricane levels. 

The MMS has reexamined the analysis for recreational resources in light of these changes. No new 

information was discovered that would alter the conclusions presented in the Multisale EIS. 

3.3.1.3.2. Impact Analysis 

The impact-producing factors associated with development and production of the Phoenix Project in 

Grid 9 that could affect recreational resources includes trash and debris, blowouts, and spilled oil. 

Chapters 4.2.1.1.10 through 4.2.1.1.13 of the Multisale EIS (USDOI, MMS, 2007) contain a discussion 

on impacts from OCS activity on recreational fishing and recreational resources and are hereby 

incorporated by reference into this PEA. 

Millions of annual visitors attracted to the coast are responsible for thousands of local jobs and 

billions of dollars in regional economic activity. Most recreational activity occurs along shorelines and 

includes such activities as beach use, boating and marinas, camping, water sports, recreational fishing, 

and bird watching. The location of the Phoenix Project precludes any visual impacts on people engaged 

in activity along the shoreline or in coastal waters. 

Very few recreational fishing trips go into deep water >100 mi (160 km) from shore and beyond the 

200-m (656-ft) isobath (the edge of the continental shelf). No impacts would be expected on recreational 

fishing. 

The oil and gas industry is not the main source for trash and debris that litters shorelines along the 

Gulf. People engaged in recreational activities along the coast are mainly responsible for this litter, as 

well as trash and debris originating onshore but ending up in the sea through deliberate or careless acts. 

Other sources of trash and debris include (1) accidental loss from staffed structures in State and Federal 

waters where hydrocarbons are produced, (2) commercial shrimping and fishing, (3) runoff from storm 

drains, (4) antiquated storm and sewage systems in older cities, and (5) commercial and recreational 

fishermen who discard plastics. The U.S. National Park Service documented the origins of trash and 

debris on South Padre Island in Texas. About 13 percent of the 63,000+ items collected were attributable 

to the offshore oil and gas industry (Miller and Echols, 1996). 

Spills that occur from Phoenix Project activity would be few (if any), volumetrically small, and 

located near project activities if they did occur. Should a blowout or large (≥1,000 bbl) oil spill occur, the 

likelihood of contact with shoreline resources is very small. Should one make landfall, it could present 

aesthetic impacts, but it is likely to be in a degraded state. Recreational beaches may be temporarily 
51 

closed during cleanup and displace and inconvenience recreational users for up to 1 year. Smaller spills 

would be subject to weathering and dispersion and would dissipate before landfall. 

Conclusion 

The proposed Phoenix Project is expected to have little impact on recreational resources. The risk of 

a large oil spill occurring because of the proposed development operations is very small. The 

displacements, inconvenience, or closure of recreational resources caused by an oil spill is below the level 

of social and economic concern. While some accidental loss of solid wastes may occur from the Phoenix 

Project or service vessels, existing mitigations and regulations that control the handling of offshore trash 

and debris would be expected to restrict these inputs so that they have a negligible impact on recreational 

resources. 

3.3.1.3.3. Cumulative Analysis 

The detailed description of recreational resources in Chapters 3.3.2 and 3.3.3 and the cumulative 

analysis in Chapters 4.5.12 and 4.5.13 of the Multisale EIS (USDOI, MMS, 2007) address the cumulative 

effects of OCS and non-OCS impact-producing factors. In the cumulative case, debris and litter derived 

from both offshore and onshore sources are likely to diminish the tourist potential of beaches and to 

degrade the ambience of shoreline recreational activities, thereby affecting the enjoyment of recreational 

beaches throughout the area. The incremental beach trash resulting from the Phoenix Project is expected 

to be minimal. 

Platforms and drilling rigs operating nearshore may affect the ambience of recreational beaches, 

especially beach wilderness areas. The sound, sight, and wakes of OCS-related and non-OCS-related 

vessels, as well as OCS helicopter and other light aircraft traffic, are occasional distractions that are 

noticed by some beach users. 

Oil that contacts the coast may preclude short-term recreational use of one or more Gulf Coast 

beaches at the park or community levels. Displacement of recreational use from impacted areas will 

occur, and a short-term decline in tourism may result. Beach use at the regional level is unlikely to 

change from normal patterns; however, closure of specific beaches or parks directly impacted by a large 

oil spill is likely during cleanup operations. The incremental contribution of the Phoenix Project to the 

cumulative impact on recreational resources is minor due to the limited effect of increased helicopter, 

vessel traffic, and marine debris on the number of beach users. The cumulative impact of OCS and State 

oil and gas activities would be minor. 

3.3.1.4. Archaeological Resources 

3.3.1.4.1. Description 

Archaeological resources are any material remains of human life or activity that are at least 50 years 

old and that are of archaeological interest. The archaeological resources regulation (30 CFR 250.194) 

provides specific authority to each MMS Regional Director to require archaeological resource surveys, 

analyses, and reports. Surveys are required prior to any exploration or development activities proposed 

on leases within the high-probability areas (NTL 2005-G07 and NTL 2006-G07). 

Archaeological resources on the OCS can be divided into two types: prehistoric and historic. A 

detailed description of these resources is provided in Chapter 3.3.4 of the Multisale EIS (USDOI, MMS, 

2007). 

3.3.1.4.2. Impact Analysis 

The impact-producing factors associated with supplemental activities of the Phoenix Project area in 

Green Canyon Blocks 236 and 237 that could affect archaeological resources include (1) direct contact or 

disturbance by the installation rig and buoy anchors or mooring chains, (2) ferromagnetic structures or 

debris on the seabed, (3) onshore development in support of the project, and (4) oil spills. Chapters 

4.2.1.1.12, 4.2.2.1.14, 4.4.13, and 4.5.14 of the Multisale EIS (USDOI, MMS, 2007) contain a detailed 

discussion of impacts (routine, accidental, and cumulative) from OCS activity and are hereby 

incorporated by reference into this PEA. 
52 

The MMS’s operational regulation at 30 CFR 250.194 requires that an archaeological survey be 

conducted prior to development of leases within the high-probability zones for historic and prehistoric 

archaeological resources. Neither lease block in the proposed Phoenix Project area of Green Canyon are 

located within MMS’s designated high-probability areas for the occurrence of prehistoric or historic 

archaeological resources. However, recent research on historic shipping routes suggests that Green 

Canyon Blocks 236 and 237 were located along the historic Spanish trade route, which therefore increases 

the probability that a historic shipwreck could be located in this area (Lugo-Fernández et al., 2007). 

Conclusion 

There is no possibility that the proposed Phoenix Project will impact prehistoric archaeological 

resources because of the extreme water depths. 

The proposed Phoenix Project is expected to have no direct or indirect impact on the inventory of 

known historical shipwrecks located in Green Canyon Blocks 236 and 237. However, impacts are 

possible on a historic shipwreck because of incomplete knowledge about the location of shipwrecks in the 

Gulf of Mexico. Direct contact between anchors and mooring lines for OCS surface structures or the 

emplacement of sea-bottom production structures could destroy or disturb important historic 

archaeological artifacts or information. Other impact-producing factors would not be expected to 

adversely affect historic archaeological resources. 

3.3.1.4.3. Cumulative Analysis 

Green Canyon Blocks 236 and 237 are located in water depths ranging between 600 and 800 m 

(1,968 and 2,625 ft), precluding the potential for prehistoric sites or artifacts. According to Garrison et al. 

(1989) and Pearson et al. (2003), the shipwreck database lists no known historic shipwrecks in Green 

Canyon Blocks 236 and 237. 

Construction of new onshore facilities or pipelines in support of OCS activity or coastal development 

unrelated to OCS activity could result in the direct physical impact to previously unidentified 

archaeological sites. This direct physical contact with an archaeological site could cause physical damage 

to, or complete destruction of, information on the prehistory or history of the region and the Nation. Each 

facility constructed must receive approval from the pertinent Federal, State, county/parish, and/or 

community involved. Onshore archaeological resources would be protected through the review and 

approval processes of the various Federal, State, and local agencies involved in permitting onshore 

activities. A detailed discussion of cumulative impacts from OCS activity can be found in Chapter 3.3.4 

of the Multisale EIS and is hereby incorporated by reference into this PEA. 

3.3.2. Human Resources and Land Use 

Human resources and land use in the WPA are characterized in Chapter 3.3.5 of the Multisale EIS 

(USDOI, MMS, 2007) and are hereby incorporated by reference into this PEA. Summaries of these 

resources follow and include (1) population, (2) infrastructure and land use, (3) employment, and (4) 

environmental justice. 

The impacts on human resources and economic activity including (1) population, (2) infrastructure 

and land use, (3) employment, and (4) environmental justice are discussed in the following sections. 

Chapters 4.2.1.1.13 and 4.2.2.1.15 of the Multisale EIS (USDOI, MMS, 2007) contain a discussion of 

impacts on land use, coastal infrastructure, demographics, economic factors, and environmental justice 

from OCS activity and are hereby incorporated by reference into this PEA. 

The human resources and economic activity evaluated in this PEA are limited to that portion of the 

GOM’s coastal zone directly or indirectly affected by OCS development and production in Grid 9. This 

economic area is concentrated primarily in Texas and Louisiana; however, multiplier effects extend into 

neighboring states as well. The impacts that result from industry activity on the Federal OCS are taking 

place in the midst of dynamic commercial and industrial enterprises that move goods and services on Gulf 

waters and that cause some of the same impact-producing factors as OCS activity. 
53 

3.3.2.1. Population 

3.3.2.1.1. Description 

Tables 3-18 through 3-30 of the Multisale EIS (USDOI, MMS, 2007) show baseline population 

projections for the potential impact areas. Baseline projections are for the impact area in the absence of 

the proposed activity. These projections include Woods & Poole’s assumptions regarding Hurricane 

Katrina’s impact on the Southeast. Table 3-34 of the Multisale EIS (USDOI, MMS, 2007) presents 

population projections for the eight counties and parishes that were the most negatively affected by 

Hurricanes Katrina and Rita in terms of population and employment losses: St. Bernard, Orleans, 

Plaquemines, Jefferson, and Cameron Parishes, Louisiana; and Hancock, Jackson, and Harrison Counties, 

Mississippi. The analysis area consists of highly populated metropolitan areas (such as the Houston 

Metropolitan Statistical Area, which dominates Subarea TX-2) and sparsely populated rural areas (as is 

much of Subarea TX-1). The GOM coastal region’s population increased by 19 percent between 1990 

and 2000 and by 9 percent between 2000 and 2006. The region’s current total population is 23.3 million. 

In the U.S., population age structures typically reflect the presence of the baby-boom generation. This 

scenario is manifested in the Gulf Coast region by the relative decline in lower age cohorts over time. 

More distinctive is the changing race and ethnic composition of the region, which has a long-standing 

tradition of cultural heterogeneity (Gramling, 1982 and 1996). While the African-American population 

increased 23.6 percent between 1990 and 2000, the growth rate has declined to 8.2 percent between 2000 

and 2006. The Hispanic population increased 53.8 percent between 1990 and 2000 and has continued to 

increase rapidly since 2000 (24.4%). This group is now the second largest race/ethnic group in the 

region, making up 25.8 percent of the Gulf Coast population. Although Asians and Pacific Islanders 

constitute a relatively small proportion of the Gulf Coast population, this group has experienced the 

highest growth rate between 1990 and 2000 (82.5%) and between 2000 and 2006 (28.2%). The white 

population has steadily declined and currently constitutes 53.6 percent of the region’s population. 

3.3.2.1.2. Impact Analysis 

No project in Grid 9 is expected to exceed the employment and population impacts associated with 

the Thunder Horse project in Grid 16. Peak-year direct, indirect, and induced employment impacts 

associated with development activities proposed for Thunder Horse, the largest development plan 

proposed to date on the OCS, is projected to be comparable to that projected for the Phoenix Project. 

Should a project comparable in size and complexity to Thunder Horse occur in Grid 9, population impacts 

in any given subarea for any given year would still not be expected to exceed 1 percent of the baseline 

population for any subarea. Minimal effects on population are projected from activities associated with 

the project. While some of the labor force is expected to be local to the service bases at Port Fourchon 

and Galveston, most of the additional employees associated with the Phoenix Project are not expected to 

require local housing. 

Conclusion 

The proposed Phoenix Project is expected to have a minimal impact on the region’s population. 

3.3.2.1.3. Cumulative Analysis 

As explained in the Multisale EIS (USDOI, MMS, 2007), the Woods & Poole population projections 

include assumptions concerning the cumulative effects of non-OCS and OCS impacts. Activity from 

OCS development and production is expected to minimally affect the larger impact areas’ demographic 

patterns or population or education levels but to moderately affect the population levels of local onshore 

areas where OCS activity is now concentrated. The impact region’s population will continue to grow at a 

slow rate because of general economic development, including OCS activity. Baseline patterns and 

factors as described in Chapter 3.3.2 would not be expected to change for the impact area as a whole. 

Some coastal subareas, Port Fourchon and Galveston, for example, would be expected to experience some 

impacts due to population growth resulting from increasing demand for OCS labor and deepwater 

production activity. These impacts could strain local infrastructure, such as schools, roads, hospitals, 

housing, and city services. 
54 

3.3.2.2. Infrastructure and Land Use 

3.3.2.2.1. Description 

The GOM OCS has one of the highest concentrations of oil and gas activity in the world. The 

offshore oil and gas industry has experienced dramatic changes over the past two decades. Most of this 

activity has been concentrated on the continental shelf off the coasts of Texas and Louisiana. The high 

level of offshore oil and gas activity in the GOM is accompanied by an extensive development of onshore 

service and support facilities. The major types of onshore infrastructure are described in Chapter 3.3.5.8 

of the Multisale EIS (USDOI, MMS, 2007) and include gas processing plants, navigation channels, oil 

refineries, pipelines and pipeline landfalls, pipecoating and storage yards, platform fabrication yards, 

service bases, terminals, and other industry-related installations such as landfills and disposal sites for 

drilling and production wastes; these descriptions are summarized below and are hereby incorporated by 

reference into this PEA. The vast majority of this infrastructure also supports oil and gas activities in 

State waters and onshore. 

A service base is a community of businesses that load, store, and supply equipment, supplies, and 

personnel needed at offshore work sites. Although a service base may primarily serve the OCS planning 

area and subarea in which it is located, it may also provide significant services for the other OCS planning 

areas and subareas. As OCS operations have progressively moved into deeper waters, larger vessels with 

deeper drafts (>27 ft or 8 m) have been phased into service mainly for their greater range of travel, greater 

speed of travel, and larger carrying capacity. Service bases with the greatest appeal for deepwater activity 

have several common characteristics: (1) a strong and reliable transportation system; (2) adequate depth 

and width of navigation channels; (3) adequate port facilities; (4) existing petroleum industry support 

infrastructure; (5) location central to OCS deepwater activities; (6) adequate worker population within 

commuting distance; and (7) insightful and strong leadership. 

Land use in the impact area varies from state to state. Louisiana’s coastal impact area is mostly vast 

areas of wetlands and small communities and industrial areas that extend inland. The coasts of Texas and 

Florida are a mixture of urban, industrial, recreational beach, wetland, forest, and agricultural areas. 

Alabama’s coastal impact area is predominantly recreational beaches and small residential and fishing 

communities. Mississippi’s coast consists of barrier islands, some wetlands, recreational beaches, and 

urban areas. 

3.3.2.2.2. Impact Analysis 

The existing oil and gas infrastructure is expected to be sufficient to handle development associated 

with the Phoenix Project. The primary onshore support base for operations will be the existing facilities 

at Port Fourchon, Louisiana. Port Fourchon has a longstanding history servicing offshore oil and gas and 

is capable of providing the services necessary for the project. It is unlikely that there will be any 

significant expansions at any existing infrastructure facilities as a result of the proposed activity. No new 

navigation channels will be required by, and current navigation channels will not change as a result of, the 

Phoenix Project. Changes in land use throughout the region as a result of the proposed activity would be 

contained and minimal. While land use in the impact area will change over time, the majority of this 

change is estimated as general regional growth. 

Activities associated with the Phoenix Project are not expected to significantly impact forms of social 

infrastructure (e.g., schools, hospitals, social services, etc.) in Port Fourchon or any of the other 

communities in the analysis area. This is due to the minimal population increase expected due to the 

project (Chapter 3.3.2.1.2). 

Spills that occur from Phoenix development and production activity would be few (if any), 

volumetrically small, and located near project activities if they did occur. Should a blowout or large oil 

spill occur as a result of Phoenix Project activity, the likelihood of contact with shoreline resources is very 

small. Smaller spills would be subject to weathering and dispersion and would likely dissipate before 

landfall. 

Conclusion 

The proposed Phoenix Project is expected to have minimal impact on the region’s existing 

infrastructure or land-use patterns. The existing oil and gas infrastructure is expected to be sufficient to 
55 

handle development associated with the Phoenix Project. Accidental events such as oil spills and 

blowouts would have no effects on land use. 

3.3.2.2.3. Cumulative Analysis 

Much of the cumulative analysis for land use and coastal infrastructure presented in Chapter 4.5.15.1 

of the Multisale EIS (USDOI, MMS, 2007) is applicable to the cumulative analysis of Grid 9 and is 

hereby incorporated by reference into this PEA and is summarized below. This cumulative analysis 

focuses on the potential direct, indirect, and induced impacts from activities in Grid 9, together with those 

of other likely future projects (including those under the OCS Program), and trends in the region on 

coastal infrastructure and land use in those areas. Land use in the analysis area will evolve over time. 

The majority of this change is estimated as general regional growth rather than activities associated with 

the OCS Program and State oil and gas activities. Except for the projected new gas processing plants (up 

to 14 assuming average retirement and no expansions and/or the addition of new capacity to replace what 

is physically depreciating at all existing facilities) and the 4-6 pipeline shore facilities, the OCS Program 

will require no new oil and gas coastal infrastructure (USDOI, MMS, 2007). There may be some 

expansion at current facilities, but the land in the analysis area is sufficient to handle development. There 

is also sufficient land to construct the projected new gas processing plants and pipeline shore facilities in 

the analysis area. While it is possible that up to 14 new, greenfield gas processing facilities could be 

developed, it is much more likely that a large share of the natural gas processing capacity that is needed in 

the industry will be located at existing facilities, using future investments for expansions and/or to replace 

depreciated capital equipment. New facilities and expansions would also support State oil and gas 

production. Thus, the results of OCS and State oil and gas activities are expected to minimally alter the 

current land use of the area. 

Shore-based OCS and State servicing should also increase very slightly in the ports of Galveston, 

Texas; Port Fourchon, Louisiana; and Mobile, Alabama. There is sufficient land designated in 

commercial and industrial parks and adjacent to the Galveston and Mobile area ports to minimize 

disruption to current residential and business use patterns. Port Fourchon, though, has limited land 

available; operators have had to create land on adjacent wetland areas. Any changes in the infrastructure 

at Port Fourchon that lead to increases in Louisiana Highway 1 (LA Hwy 1) usage will contribute to the 

increasing deterioration of the highway. In the absence of the planned expansions, LA Hwy 1 would not 

be able to handle future OCS and State activities. Additional OCS activity will further strain Lafourche 

Parish’s social infrastructure as well, such as local schools and the water system. 

Other ports in the analysis area that have sufficient available land plan to make infrastructure 

changes. Since the State of Florida and many of its residents reject any mineral extraction activities off 

their coastline, oil and gas businesses are not expected to be located there. 

The incremental contribution of the Phoenix Project to the cumulative impacts on land use and coastal 

infrastructure are expected to be minor. Of the new coastal infrastructure projected as a result of the OCS 

Program, none are expected to be constructed as a result of the proposed project. The proposed project 

would contribute to a very small percentage of the projected OCS-related activity at Port Fourchon. 

3.3.2.3. Employment 

3.3.2.3.1. Description 

Table 3-41 of the Multisale EIS (USDOI, MMS, 2007) contains the analysis area’s baseline 

employment projections by MMS-defined EIA. These projections are based on the Woods & Poole’s 

Complete Economic and Demographic Data Source (Woods & Poole Economics, Inc., 2006) and assume 

the continuation of existing social, economic, and technological trends at the time of the forecast. 

Therefore, the projections include employment associated with the continuation of current patterns in 

OCS leasing activity as well as the continuation of trends in other industries important to the region. 

These projections also include Woods & Poole’s projections regarding Hurricanes Katrina and Rita’s 

impact on the Southeast. 

Average annual employment growth projected from 2005 through 2030 ranges from a low of 1.22 

percent for EIA LA-4 to a high of 2.50 percent for EIA FL-1 in the western panhandle of Florida. Over 

the same time period, employment for the United States is expected to grow at about 1.57 percent per 
56 

year, while the GOM economic impact analysis area is expected to grow at about 1.73 percent per year. 

As described above, this represents growth in general employment for the EIA’s. 

The industrial composition for the EIA’s adjacent to the WPA and adjacent to the CPA is similar. In 

2005, the top three ranking sectors in terms of employment in all EIA’s in the analysis area, except FL-4, 

were the services, retail trade, and State and local government sectors—with the service industry ranking 

number one in all EIA’s and retail trade ranking second in all EIA’s, except FL-2, where State and local 

government is second. In FL-4, the top three rankings sectors were services; retail trade; and finance, 

insurances and real estate, in that order, with State and local government a close fourth. In EIA’s TX-1, 

LA-1, LA-3, and FL-2, construction ranks fourth; in EIA’s AL-1, MS-1, and TX-2, manufacturing ranks 

fourth; in EIA’s LA-4, TX-3, and FL-3, finance, insurance, and real estate ranks fourth; and in EIA LA-2, 

mining ranks fourth. 

In the Multisale EIS, MMS used data from Woods & Poole’s Complete Economic and Demographic 

Data Source (Woods & Poole Economics, Inc., 2006) for baseline population and employment estimates 

over the 40-year life of a typical proposed CPA lease sale. The 2007 Woods & Poole data became 

available in late August 2007 and contains their revised estimates regarding the economic and 

demographic impacts of the 2005 hurricanes on the Gulf region (Woods & Poole Economics, Inc., 2007). 

In the new data, population, income, and employment declined from 2005 to 2006 by 76 percent in St. 

Bernard Parish, Louisiana; 51 percent in Orleans Parish, Louisiana; 22 percent in Plaquemines Parish, 

Louisiana; 19 percent in Cameron Parish; Louisiana; 13 percent in Hancock County, Mississippi; and 11 

percent in Harrison County, Mississippi. In each case, these losses were less than those that were in the 

Woods & Poole 2006 data. The 2007 data also have revised population and employment gains because of 

Hurricane Katrina displacement: 9 percent in Pearl River County, Mississippi; 7 percent in Tangipahoa 

Parish, Louisiana; 5 percent in St. John the Baptist Parish, Louisiana; 5 percent in East Baton Rouge 

Parish, Louisiana; and 4 percent in St. Charles Parish, Louisiana from 2005 to 2006. In each case, these 

gains were less than those that were in the 2006 data. 

Additional supplemental information is available regarding current economic conditions in the GOM 

region, particularly as it relates the recovery to date from the 2005 hurricanes. However, this new 

information (summarized below) does not in any way change the baseline population and employment 

projections used to analyze impacts of a typical CPA sale and the OCS Program, the methodologies used, 

or the conclusions presented in the Multisale EIS. 

More than 2 years after Hurricanes Katrina and Rita the recovery remains uneven throughout the 

areas originally affected. Areas where the most severe problems remain are Orleans and St. Bernard 

Parishes, Louisiana; and Hancock County, Mississippi. Affordable housing continues to be a problem in 

these areas, particularly in New Orleans. Adding to the problem is the high cost of insurance and building 

materials, causing many prospective developers to postpone projects until these issues are better resolved. 

Recovery is well underway in Jefferson and Calcasieu Parishes, Louisiana, as well as in Biloxi, Gulfport, 

and Pascagoula, Mississippi; and Bayou La Batre, Alabama. Recovery is driving expansion in East Baton 

Rouge and St. Tammany Parishes, Louisiana; Jackson, Hattiesburg, and Laurel, Mississippi; and Gulf 

Shores and Mobile, Alabama. The measures of recovery are the functions of local government, 

population, crime, economic and fiscal effects, local government budgets, housing, and labor (Rowley, 

2007). 

Researchers continue to study the employment impacts of the 2005 hurricane season. The Bureau of 

Labor Statistics did a special review of the employment impacts of Hurricane Katrina and found that St. 

Bernard, Orleans, and Jefferson Parishes had the largest percent declines in employment between 

September 2004 and September 2006 (38%, 27%, and 24.5%, respectively). In the 2 months following 

Hurricane Katrina, nonfarm payroll employment in Louisiana fell by 241,000, a decline of 12 percent; in 

the New Orleans metro area, employment declined by 215,000, or 35 percent. In the New Orleans metro 

area in June 2006, it was 30 percent below the level a year earlier. Total nonfarm employment in 

Louisiana decreased by 184,600 jobs or 9.6 percent from September 2004 to September 2005, and in May 

2006, the year-to-year loss was 177,700 jobs or 9.1 percent (U.S. Dept. of Labor, Bureau of Labor 

Statistics, 2006; pages 2, 4, 6, 8, 27, and 28). However, more recent data show nonfarm payroll 

employment in Louisiana increasing 3.8 percent between April 2006 and April 2007 (one of the largest 

over-the-year percentage gains in employment for a State), or an increase of 69,500 from 1,835,700 to 

1,905,200 (U.S. Dept. of Labor, Bureau of Labor Statistics, 2007). 

Estimating employment data has proven more difficult post-Katrina, and some previous estimates are 

being revised as data-gathering limitations are addressed. For example, the Atlanta Federal Reserve Bank 
57 

announced a revision to their employment estimates for Louisiana from 1,766,400 to 1,844,300 (an 

increase of 77,900 or 4.4%) between March 2005 and March 2006. Much of the revision was to account 

for job growth in the State’s construction industry that had been underestimated due to survey sampling 

issues (such as identifying and sampling new construction businesses). Professional and business 

services is another industry where employment in Louisiana appears to have been originally 

underestimated (Federal Reserve Bank of Atlanta, 2006). 

Researchers also continue to examine the impacts of the 2005 hurricane season on businesses in the 

region. For example, a Louisiana State University report on the hurricanes’ effect on businesses 

comparing the second quarter of 2005 with the second quarter of 2006 concludes that, after a decline of 

over 5,000 in the number of employers (5.3%), the entire State of Louisiana had 2,270 fewer employers 

(2.3%) one year after the hurricanes (Terrell and Bilbo, 2007). The business failure rate in the year after 

the storms was 11.7 percent for the State as a whole compared with 26.5 percent for the five-parish 

Southeast region. 

3.3.2.3.2. Impact Analysis 

The importance of the oil and gas industry to the coastal communities of the GOM is significant, 

particularly in Louisiana, eastern Texas, and coastal Alabama. This economic analysis focuses on the 

potential direct, indirect, and induced impacts of the OCS oil and gas industry on the population and 

employment of the counties and parishes in the impact region. 

Peak-year direct, indirect, and induced employment associated with development activities proposed 

for Thunder Horse in Grid 16, the largest development plan proposed to date on the OCS, was projected 

at about 1,500 jobs (USDOI, MMS, 2002). Total peak-year employment projections for activities 

resulting from the Marco Polo project in Grid 13 were comparable with Thunder Horse, 1,565 jobs per 

year throughout all subareas: 795 direct, 350 indirect, and 420 induced (USDOI, MMS, 2003a). Phased 

development and production is proposed under the Phoenix Project, with production beginning in 2008 

and ending in 2018. The total peak-year employment from the Phoenix Project is not expected to exceed 

these projects and is expected to occur between 2009 and 2013. 

The Phoenix Project is expected to have minimal impacts on employment throughout all 13 of the 

EIA’s identified above in Chapter 3.3.1.1 (Socioeconomic Impact Area). The majority of employment 

resulting from the Phoenix Project is expected to occur in EIA’s TX-1, TX-2, TX-3, LA-1, LA-2, and 

LA-3 because of the location of the project and because the oil and gas industry is best established in 

these areas. Even assuming that all 1,500 jobs would occur in any single EIA in Texas or Louisiana, a 

highly unlikely scenario but one used to evaluate maximum possible impacts, employment does not 

exceed 1 percent of the total baseline employment projections for any given EIA during 2009 through 

2013. This demand is expected to be met primarily with the existing available labor force. 

Should a blowout or large oil spill occur, the likelihood of contact with shoreline resources is very 

small. Smaller spills would be subject to weathering and dispersion and would likely dissipate before 

landfall. The potential positive and negative employment impacts of an oil spill are characterized in 

Chapter 4.4.14.3 of the Multisale EIS (USDOI, MMS, 2007) and are hereby incorporated by reference 

into this PEA. The net employment impacts of a spill are expected to be minimal. 

Conclusion 

The proposed Phoenix Project is expected to have minimal impacts on employment in the Texas, 

Louisiana, Mississippi, Alabama, and Florida EIA’s. The project is expected to generate less than a 1 

percent increase in employment in any of these subareas. 

3.3.2.3.3. Cumulative Analysis 

Much of the cumulative analysis for economic factors presented in Chapter 4.5.15.3 of the Multisale 

EIS (USDOI, MMS, 2007) is applicable to this cumulative employment analysis and is hereby 

incorporated by reference into this PEA, and is summarized below. This cumulative employment analysis 

focuses on the potential direct, indirect, and induced employment impacts from activities in Grid 9, 

together with those of other likely future projects (including those under the OCS Program), and trends in 

the region. Most approaches to analyzing cumulative effects begin by assembling a list of “other likely 

projects and actions” that will be included with the proposed action for analysis. However, no such list of 
58 

future projects and actions could be assembled that would be sufficiently current and comprehensive to 

support a cumulative analysis for all 132 of the coastal counties and parishes in the analysis area over the 

time period of analysis. Instead of an arbitrary assemblage of future possible projects and actions, this 

analysis employs the baseline employment projections from Woods & Poole Economics, Inc. (2007) used 

above in Chapter 3.3.2.3.2 to define the contributions of other likely projects, actions, and trends to the 

cumulative case. These projections represent a more comprehensive and accurate appraisal of cumulative 

conditions than could be generated using the traditional list of possible projects actions. 

The incremental contribution of the Phoenix Project to the cumulative employment impacts are 

expected to be minor. No project in Grid 9 is expected to exceed the employment impacts associated with 

the Thunder Horse project in Grid 16. Should a project comparable in size and complexity with Thunder 

Horse occur in Grid 9, employment impacts in any given subarea for any given year would still not be 

expected to exceed 1 percent of the baseline employment for any subarea (Chapter 3.3.2.3.2). 

Employment demand will continue to be met primarily with the existing population and available 

labor force in most EIA’s. The MMS does expect some employment will be met through in-migration; 

however, this level is projected to be small and localized. Port Fourchon is experiencing full 

employment, housing shortages, and stresses on local infrastructure—roads (LA Hwy 1), water supply, 

schools, hospitals, etc. Port Fourchon is a focal point for OCS development, especially deepwater OCS 

operations. The Port (and the surrounding community and infrastructure) is still experiencing increased 

activity as a result of the 2005 hurricane season. Any additional employment, particularly new residential 

employment, and the resultant strain on infrastructure, are expected to have a significant impact on the 

area. In addition, ports throughout the Gulf are experiencing labor shortages for higher skilled positions 

as electricians, fitters, crane operators, and boat captains, an issue that existed prior to the 2005 hurricane 

season. This may lead to additional in-migration to these areas to fill these positions. 

3.3.2.4. Environmental Justice 

3.3.2.4.1. Description 

On February 11, 1994, President William J. Clinton issued Executive Order 12898, Federal Actions 

to Address Environmental Justice in Minority Populations and Low-Income Populations, which directs 

Federal agencies to assess whether their actions have disproportionate environmental effects on people of 

ethnic or racial minorities or people with low incomes. Those environmental effects encompass human 

health, social, and economic consequences. The Federal agency in charge of the proposed action must 

provide opportunities for community input during the NEPA process (See Chapter 4 for a discussion of 

consultation and coordination.). There are no environmental justice issues in the actual offshore Gulf of 

Mexico OCS planning areas; however, environmental justice concerns may be related to nearshore and 

onshore activities in support of the proposed Phoenix Project. Environmental justice issues are in two 

categories—those related to routine operations and those related to accidental events. Issues related to 

routine operations center on increases in onshore activity (such as employment, migration, commuter 

traffic, and truck traffic) and on additions to or expansions of the infrastructure supporting this activity 

(such as fabrication yards, supply ports, and onshore disposal sites for offshore waste). Issues related to 

accidents focus on oil spills. 

3.3.2.4.2. Impact Analysis 

Federal agencies are directed by Executive Order 12898 to assess whether their actions would have a 

disproportionate and negative effect on the environment and health of people of ethnic or racial minorities 

or those with low income. The existing onshore facilities that can support the projected developments 

within Grid 9 are well established along the Gulf Coast, and no disproportionate impacts on ethnic or 

racial minorities or poor people would result from their continued operation. 

Conclusion 

The proposed Phoenix Project is expected to have no impacts on existing equities of environmental 

justice. 
59 

3.3.2.4.3. Cumulative Analysis 

Future years may bring expansion or upgrading of existing onshore facilities that support OCS 

activities in Grid 9, but entirely new development is unlikely. The existing coastal support facilities are 

well established, and no disproportionate effects on ethnic or racial minorities or poor people would be 

expected to result from their continued operation. In the GOM coastal area, the contribution of the 

Phoenix Project to the cumulative effects of all activities and trends affecting environmental justice issues 

is expected to be negligible to minor. Chapter 4.5.15.4 of the Multisale EIS (USDOI, MMS, 2007) 

analyzes cumulative environmental justice effects in Lafourche Parish, Louisiana. 

4. CONSULTATION AND COORDINATION 

Necessary consultation and coordination for this proposed action was conducted during the 

preparation of the Multisale EIS (USDOI, MMS, 2007). The State of Louisiana has an approved Coastal 

Zone Management (CZM) Program. Therefore, certificates of coastal zone consistency from the State 

were required for the proposed activities. The MMS mailed the DOCD and other required and necessary 

information to the Louisiana Department of Natural Resources for CZM concurrence on January 7, 2008. 

The State of Louisiana, on January 25, 2008, provided a letter with a Certificate of Coastal Zone 

Consistency with the State’s CZM Program; the letter was received by MMS on January 28, 2008. The 

MMS published a description of ERT’s proposed action in the Times-Picayune on January 21, 2008, and 

the Houma Courier on January 21, 2008. The description provided the public with a Notice of 

Preparation of an EA and outlined the activities ERT proposed for the Phoenix Project. The Notice 

requested that interested parties submit comments to MMS on issues that should be addressed in the PEA. 

The 30-day comment period ended on February 20, 2008. No comments were received during this 

period. 

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6. PREPARERS 

NEPA Coordinator 

Alvin Jones Physical Scientist 

Contributors 

Pat Adkins Information Management Specialist 

David Ball Archaeologist—Archaeological Issues 

Greg Boland Biologist—Fisheries and Benthic Issues 

Darice Breeding Physical Scientist—Hydrocarbon Spill Issues 

Donald Glenn Biologist—Marine Mammals and Sea Turtles Issues 

Mike Gravois GIS/Visual Information Specialist 

Larry Hartzog Biologist—Barrier Beaches and Dune Issues 

Bonnie Johnson Environmental Scientist—Coastal Zone Management Issues 

Jill Leale GIS/Visual Information Specialist 

Harry Luton Sociologist—Recreation and Environmental Justice Issues 

Stacie Meritt-Hendon Physical Scientist—Air Quality Issues 

Margaret Metcalf Physical Scientist—Water Quality Issues 

Deborah Miller Technical Publications Editor 

Dave Moran Environmental Scientist—Marine and Coastal Birds Issues 

Maureen Mulino Marine Biologist—Commercial Fisheries Issues 

Cathy Rosa Environmental Assessment Program Specialist 

Kristen Strellec Economist—Socioeconomic Issues 

Reviewers and Supervisors 

Gary Goeke Supervisor, NEPA/CZM Coordination Unit 

Dennis Chew Chief, Environmental Assessment Section 
69 

7. APPENDICES 

Appendix A. Waste and Discharges Review 

Appendix B. Accidental Oil-Spill Review 
Appendix A 

 

Waste and Discharges Review 
A-3 

APPENDIX A. WASTE AND DISCHARGES REVIEW 

The discharge of wastes into offshore waters is regulated by USEPA under the authority of the Clean 

Water Act. No wastes generated during oil and gas operations can be discharged overboard unless they 

meet the standards required within an NPDES permit. All of the waste types generated from the proposed 

exploration activities for Phoenix will be either (1) discharged overboard in compliance with NPDES 

requirements or (2) transported to shore for disposal in permitted or licensed commercial facilities or for 

recycling. The wastes for overboard discharge and transport to shore for recycling or disposal are 

summarized in Tables A-1 and A-2, respectively. 

Wastes generated during the development and production activities of the Phoenix Project consist of 

(1) drill fluids; (2) drill cuttings (WBF); (3) sanitary and domestic wastes; (4) deck drainage; (5) well 

treatment, workover, or completion fluids; (6) excess cement; (7) produced water; (8) used oil; and (9) 

solid trash and debris. The projected amounts are listed in Tables A-1 and A-2. Additional project 

discharges may include (10) uncontaminated seawater used for cooling, desalinization, and ballast; (11) 

bilge water, and (12) chemically treated seawater or freshwater. 

Well treatment, completion, and workover fluids would be collected in a separator. Aqueous fluids 

would be routed to the water treatment system for discharge. Nonaqueous fluids would be collected in 

drums or the slop tank of a supply vessel to be transported to shore for disposal. 

Routine sanitary and domestic wastes necessarily arise from people working offshore on drilling rigs, 

production platforms, and support vessels. 

Deck drainage effluent is primarily rainwater containing residual oil and grease from equipment 

washwater and rainwater. Overboard discharge of deck drainage is governed by the NPDES permit 

requirement for no visible oil sheen. A maximum for deck drainage during daily operation is estimated 

by MMS to be 3,000 bbl per month. 

Table A-1 

 

Projected Ocean Discharges from the Phoenix Project 

Type of Waste Total Amount Discharged Discharge Rate Discharge Method 

Water-based mud 2,500 bbl/well 220 bbl/hr Overboard 

Drill cuttings associated 

with water-based 

drilling fluids 

2,000-3,000 bbl/well 

Overboard 

Muds and cuttings at the 

seafloor 

Gel–5,000 bbl 

WBM–8,000 bbl 

Cuttings–20,000 bbl 

Seawater and caustic–4,800 bbl 

Cement–100 bbl 

Overboard 

Sanitary waste 864,000 gallons 20 gal/person/day Chlorinate and discharge 

Domestic waste 1,296,000 gallons 30 gal/person/day Remove floating solids 

and discharge 

Deck drainage 0-365 bbl/day 1 bbl/day 

(dependent on rainfall) 

Treat for oil and grease 

and discharge 

Well treatment, 

workover, or completion 

fluids 

1,300 bbl/well 

Discharge used fluids 

overboard, return excess 

to shore for credit 

Produced water 250,000 bbl/year 1,000 bbl/day 
A-4 

Table A-2 

 

Wastes for Transport to Shore on the Proposed Phoenix Project 

Type of Waste—

Approximate Composition Amount Name/Location of Disposal Facility 

Treatment and/or Storage, Transport, 

and Disposal Method 

Trash and debris 216 ft3 Riverside Recycle Transport to shore base for recycle 

and burn 

Hazardous liquid—used oil 10 bbl Riverside Recycle Transport to shore base for recycle 
Appendix B 

 

Accidental Oil-Spill Review 
B-3 

ANALYSIS OF THE POTENTIAL FOR AN ACCIDENTAL OIL SPILL 

AND THE POTENTIAL FOR IMPACTS 

FROM THE PHOENIX DEVELOPMENT PROJECT – GRID 9, 

GREEN CANYON BLOCKS 236 AND 237 

Introduction 

The National Environmental Policy Act requires Federal agencies to consider potential environmental 

impacts (direct, indirect, and cumulative) of proposed actions as part of agency planning and 

decisionmaking. The NEPA analyses address many issues relating to potential impacts, including issues 

that may have a very low probability of occurrence, but which the public considers important or for which 

the environmental consequences could be significant. 

The past several decades of spill data show that accidental oil spills (>1,000 bbl) associated with oil 

and gas exploration and development are low-probability events in Federal OCS waters of the GOM, yet 

the issue of oil spills is important to the public. This appendix summarizes key information about the 

probability of accidental spills from offshore oil and gas activities in the GOM. 

Spill Prevention 

The MMS has comprehensive pollution-prevention requirements that include numerous redundant 

levels of safety devices, as well as inspection and testing requirements to confirm that these devices work. 

Many of these requirements have been in place since about 1980. Spill trends analysis for the GOM OCS 

shows that spills from facilities have decreased over time, indicating that MMS’s engineering and safety 

requirements have minimized the potential for spill occurrence and associated impacts. Details regarding 

MMS’s engineering and safety requirements can be found at 30 CFR 250.800 Subpart H. 

OCS Spills in the Past 

This summary of past OCS spills presents data for the period 1985-1999. The 1985-1999 time period 

was chosen to reflect more modern engineering and regulatory requirements and because OCS spill rates 

are available for this period. For the period 1985-1999, there were no spills ≥1,000 bbl from OCS 

platforms, eight spills ≥1,000 bbl from OCS pipelines, and no spills ≥1,000 bbl from OCS blowouts 

(Tables B-1 through B-3). The Multisale EIS and EPA Sale 224 Supplemental EIS (USDOI, MMS, 

2007a and b, respectively) provide additional information on past OCS spills. 

Estimating Future Potential Spills 

The MMS estimates the risk of future potential spills by multiplying variables to result in a numerical 

expression of risk. These variables include the potential of a spill occurring based on historical OCS spill 

rates and a variable for the potential for a spill to be transported to environmental resources based on 

trajectory modeling. The following subsections describe the spill occurrence and transport variables used 

to estimate risk and the risk calculation for the proposed action.

Spill Occurrence Variable (SOV) Representing the Potential for a Spill 

The SOV is derived based on past OCS spill frequency. That is, data from past OCS spills are used to 

estimate future potential OCS spills. The MMS has estimated spill rates for spills from the following 

sources: facilities, pipelines, and drilling. 

Spill rates for facilities and pipelines have been developed for several time periods and an analysis of 

trends for spills is presented in Update of Comparative Occurrence Rates for Offshore Oil Spills 

(Anderson and LaBelle, 2000). Spill rates for the most recent period analyzed, 1985-1999, are presented 

here. Data for this recent period should reflect more modern spill-prevention requirements. A review of 
B-4 

recent historical data following Hurricane Katrina indicates that there has been no change in the rates 

identified in the aforementioned study/assessment. 

Spill rates for facilities and pipelines are based on the number of spills per volume of oil handled. 

Spill rates for blowouts are based on the number of blowouts with a release of oil per number of wells 

drilled. Spill rates for the period 1985-1999 are shown in Table B-4. It should be noted that there were 

no platform or blowout spills ≥1,000 bbl for the period 1985-1999. Use of “zero” spills would result in a 

zero spill rate. To allow for conservative future predictions of spill occurrence, a spill number of one was 

“assigned” to provide a non-zero spill rate for blowouts. The spill period was expanded to 1980 to 

include a spill for facilities. While there were no facility or blowout spills during the 1985-1999 period 

for which data are available, spills could occur in the future. In fact, a pipeline spill ≥1,000 bbl was 

reported subsequent to this period, so it is reasonable to include a spill to provide a non-zero spill rate. 

Spill rates are combined with site-specific data on production or pipeline volumes or number of wells 

being drilled to result in a site-specific SOV. 

Transport Variable (TV) Representing the Potential for a Spill to be Transported to 

Important Environmental Resources 

The TV is derived using a trajectory model. This model predicts the direction that winds and currents 

would transport spills. The model uses an extensive database of observed and theoretically computed 

ocean currents and fields that represent a statistical estimate of winds and currents that would occur over 

the life of an oil and gas project, which may span several decades. This model produces the TV that can 

be combined with other variables, such as the SOV, to estimate the risk of future potential spills and 

impacts. 

Risk Calculation for the Proposed Action 

Energy Resource Technology, Inc. proposes to drill and complete two new wells in Green Canyon 

Block 236, drill and complete four new wells in Green Canyon Block 237, install a subsea manifold, clear 

the area of debris, and produce from a floating production unit. Table B-5 presents an estimate of spill 

risk from the facility and to resources. The risk estimate for the facility was calculated using the spill rate 

of 0.13 per billion barrels of oil produced, the estimated production for the proposed action, and oil-spill 

trajectory calculations. 

The coastline and associated environmental resources are presented in Table B-5. The final column 

in Table B-5 presents the result of combining the SOV’s and the TV’s. The risk of a coastal spill impact 

from the facility could be considered to be so low as to be near zero. 

The Multisale EIS and EPA Sale 224 Supplemental EIS (USDOI, MMS, 2007a and b, respectively) 

provide additional information on spills and potential impacts. The following section provides additional 

information regarding MMS’s spill-response preparedness requirements. 

Spill Response 

The MMS has extensive requirements for preparedness to respond to a spill in the event of an 

accidental spill. This section presents information on MMS requirements for spill-response preparedness. 

MMS Spill-Response Program 

The MMS Oil-Spill Program oversees the review of oil-spill response plans, coordinates inspection of 

oil-spill response equipment, and conducts unannounced oil-spill drills. This program also supports 

continuing research to foster improvements in spill prevention and response. Studies funded by MMS 

address issues such as spill prevention and response, in-situ burning, and dispersant use. 

In addition, MMS works with USCG and other members of the multiagency National Response 

System to further improve spill-response capability in the GOM. The combined resources of these groups 

and the resources of commercially contracted oil-spill response organizations result in extensive 

equipment and trained personnel for spill response in the GOM. 
B-5 

Spill Response for this Project 

The subject operator has an oil-spill response plan on file with MMS and has a current contract with 

the offshore oil-spill response organization Clean Gulf Associates. 

Potential spill sources during the life of this development project (5 years) would include an 

accidental blowout (worst case estimated to be approximately 21,000 bbl/day), a spill of liquid oil stored 

on the platform (approximately 1,850 bbl total storage capacity including flowlines on the facility), a spill 

of liquid oil stored on the semi-submersible rig (approximately 19,000 total storage capacity), a spill of 

liquid oil stored on the associated vessels (capacity of the largest vessel is 2,000 bbl), or a spill from the 

associated oil flowlines or the export pipelines. The operator has demonstrated spill-response 

preparedness for accidental releases in their oil-spill response plan. Details regarding a proposed 

response to this facility are included in the proposed plan. 

The MMS will continue to verify the operator’s capability to respond to oil spills via the MMS 

Oil-Spill Program. The operator is required to keep their oil-spill response plan up-to-date in accordance 

with MMS regulations. The operator must also conduct an annual drill to demonstrate the adequacy of 

their spill preparedness. 

Table B-1 

 

Historical Record of OCS Spills ≥1,000 Barrels from OCS Facilities, 1985-1999 

Spill Date 

Area and Block 

(water depth and 

distance from shore) 

Volume Spilled 

(barrels) Cause of Spill 

No OCS facility spills >1,000 bbl during the period 1985-1999. 

Table B-2 

 

Historical Record of OCS Spills ≥1,000 Barrels from OCS Pipelines, 1985-1999 

Spill Date 

Area and Block 

(water depth and 

distance from shore) 

Volume Spilled 

(barrels) Cause of Spill 

February 7, 1988 South Pass 60 

(75 ft, 3.4 mi) 

15,576 Service vessel’s anchor damaged 

pipeline 

January 24, 1990 Ship Shoal 281 

(197 ft, 60 mi) 

14,423* Anchor drag, flange and valve broke 

off 

May 6, 1990 Eugene Island 314 

(230 ft, 78 mi) 

 4,569 Trawl drag pulled off valve 

August 31, 1992 South Pelto 8 

(30 ft, 6 mi) 

 2,000 Hurricane Andrew, loose drilling rig’s 

anchor drag damaged pipeline 

November 22, 1994 Ship Shoal 281 

(197 ft, 60 mi) 

 4,533* Trawl drag 

January 26, 1998 East Cameron 334 

(264 ft, 105 mi) 

 1,211* Service vessel’s anchor drag damaged 

pipeline during rescue operation 

September 29, 1988 South Pass 38 

(110 ft, 6 mi) 

 8,212 Hurricane Georges, mudslide parted 

pipeline 

July 23, 1999 Ship Shoal 241 

(133 ft, 50 mi) 

 3,189 Jack-up barge sat on pipeline 

*condensate 
B-6 

Table B-3 

Historical Record of OCS Spills ≥1,000 Barrels from OCS Blowouts, 1985-1999 

Spill Date 

Area and Block 

(water depth and 

distance from shore) 

Volume Spilled 

(barrels) Cause of Spill 

No OCS blowout spills ≥1,000 bbl during the period 1985-1999. 

Table B-4 

 

Spill Rates Used to Estimate the Future Potential for Spills 

Spill Source 

Volume of Oil 

Handled in 

Billions of Barrels 

Number of 

Wells Drilled 

No. of Spills 

≥1,000 Barrels 

Risk of Spill 

from Facilities 

or Pipelines per 

Billion Barrels 

Risk of Spill 

from Drilling 

Blowout per 

Well

Facilities 7.41 a Not Applicable 1a >0 to <0.13 Not Applicable 

Pipelines 5.81 Not Applicable 8 1.38 Not Applicable 

Drilling Not Applicable 14,067 1b Not Applicable >0 to <0.00007 a

 There were actually zero spills ≥1,000 bbl from facilities during the period 1985-1999. The data shown 

represent 1980-1999. The spill period for facility spills was expanded to 1980 to include a spill for facilities to 

result in a nonzero risk. 

b

 There have been no spills ≥1,000 bbl from blowouts during the period 1985-1999. One spill was “assigned” to 

provide a non-zero spill rate. 

c

 There were no facility or blowout spills ≥1,000 bbl for the period 1985-1999; however, a non-zero spill rate was 

calculated by expanding the facility period to 1980 and by “assigning” a blowout spill. Therefore, the spill rates 

for these categories are presented as >0 but below the rates calculated by expanding the data period and assigning 

a spill. 
B-7 

Table B-5 

 

Spill Risk Estimate for Facilities1

Environmental 

Resource 

(county/parish) 

Spill Occurrence 

Variable2

(%) 

Transport Variable for Spill 

Launch Area (LA) 433

 

within 3/10/30 Days 

(%) 

Spill Risk1, 4

within 3/10/30 Days 

for LA 43 

(%) 

Matagorda, Tex. 0.47 <0.5/<0.5/2 <0.5/<0.5/<0.5 

Brazoria, Tex. 0.47 <0.5/<0.5/1 <0.5/<0.5/<0.5 

Galveston, Tex. 0.47 <0.5/<0.5/3 <0.5/<0.5/<0.5 

Jefferson, Tex. 0.47 <0.5/<0.5/2 <0.5/<0.5/<0.5 

Cameron, La. 0.47 <0.5/1/7 <0.5/<0.5/<0.5 

Vermilion, La. 0.47 <0.5/<0.5/3 <0.5/<0.5/<0.5 

Iberia, La. 0.47 <0.5/<0.5/1 <0.5/<0.5/<0.5 

St Mary, La. 0.47 <0.5/<0.5/<0.5 <0.5/<0.5/<0.5 

Terrebonne, La. 0.47 <0.5/<0.5/3 <0.5/<0.5/<0.5 

Lafourche, La. 0.47 <0.5/<0.5/1 <0.5/<0.5/<0.5 

Jefferson, La. 0.47 <0.5/<0.5/<0.5 <0.5/<0.5/<0.5 

Plaquemines, La. 0.47 <0.5/<0.5/2 <0.5/<0.5/<0.5 

1

 This combined risk analysis covers only the FPU and subsea wells since the right-of-way pipeline application 

associated with the project has not yet been submitted and is likely to cover additional spill launch areas. A 

determination of these spill launch areas is not practical at this time since the exact route of the projected 

right-of-way pipeline has not been officially proposed by the operator; only tentative plans for the pipeline 

have been disclosed. However, since a spill from a pipeline transporting the production of the FPU would 

result in a spill occurrence variable of only 0.5%, the combined risk of occurrence and contact from a leak 

from the ROW pipeline at the FPU site would also be <0.5%. 

2

 The percent chance of a spill event occurring from the proposed Phoenix activities. 

3

 The percent chance that winds and currents will move a point projected onto the surface of the Gulf 

beginning within the area of the proposed project and ending at specified shoreline segments or environmental 

resources within 30 days. These are the results of a numerical model that calculates the trajectory of a drifting 

point projected onto the surface of the water using temporally and spatially varying winds and ocean current 

fields. These probabilities do not factor in the risk of spill occurrence, consideration of the spill size, any spill 

response or cleanup actions, or any dispersion and weathering of the slick with time. Model results used are 

for spill launch areas C43 (i.e., CPA, site number). 

4

 The probability of a spill occurring and contacting identified environmental features represents the weighted 

risk that accounts for both the risk that a large spill will occur and the risk that it will contact locations where 

the resources occur, given the assumptions already described in (1) and (2). 

References 

Anderson, C.M. and R.P. LaBelle. eds. 2000. Update of comparative occurrence rates for offshore oil 

spills. Spill Science & Technology Bulletin. 6(5-6):303-321, October-December 2000. 

U.S. Dept. of the Interior. Minerals Management Service. 2007a. Gulf of Mexico OCS oil and gas lease 

sales: 2007-2012; Western Planning Area Sales 204, 207, 210, 215, and 218; Central Planning Area 

Sales 205, 206, 208, 213, 216, and 222—final environmental impact statement. 2 volumes. U.S. 

Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. 

OCS EIS/EA MMS 2007-018. 
B-8 

U.S. Dept. of the Interior. Minerals Management Service. 2007b. Gulf of Mexico OCS oil and gas 

Lease Sale 224: Eastern Planning Area—final supplemental environmental impact statement. U.S. 

Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. 

OCS EIS/EA MMS 2007-060. 
The Department of the Interior Mission

As the Nation's principal conservation agency, the Department of the Interior has responsibility 

for most of our nationally owned public lands and natural resources. This includes fostering 

sound use of our land and water resources; protecting our fish, wildlife, and biological diversity; 

preserving the environmental and cultural values of our national parks and historical places; 

and providing for the enjoyment of life through outdoor recreation. The Department assesses 

our energy and mineral resources and works to ensure that their development is in the best 

interests of all our people by encouraging stewardship and citizen participation in their care. 

The Department also has a major responsibility for American Indian reservation communities 

and for people who live in island territories under U.S. administration. 

The Minerals Management Service Mission 

As a bureau of the Department of the Interior, the Minerals Management Service's (MMS) 

primary responsibilities are to manage the mineral resources located on the Nation's Outer 

Continental Shelf (OCS), collect revenue from the Federal OCS and onshore Federal and Indian 

lands, and distribute those revenues. 

Moreover, in working to meet its responsibilities, the Offshore Minerals Management Program 

administers the OCS competitive leasing program and oversees the safe and environmentally 

sound exploration and production of our Nation's offshore natural gas, oil and other mineral 

resources. The MMS Minerals Revenue Management meets its responsibilities by ensuring the 

efficient, timely and accurate collection and disbursement of revenue from mineral leasing and 

production due to Indian tribes and allottees, States and the U.S. Treasury. 

The MMS strives to fulfill its responsibilities through the general guiding principles of: (1) being 

responsive to the public's concerns and interests by maintaining a dialogue with all potentially 

affected parties and (2) carrying out its programs with an emphasis on working to enhance the 

quality of life for all Americans by lending MMS assistance and expertise to economic 

development and environmental protection.